Does Science Have a Role in Risk Analysis? The Case of the Brent Spar and Other Cautionary Tales. Dr. A. L. Rice, Southampton Oceanography Centre, Empress Dock, Southampton SO 14 3ZH
On 30 April 1995, Greenpeace activists boarded
the Brent Spar, a decommissioned oil storage buoy which Shell
Expro, its owners, intended to dispose of in some 2300m of water
about 150 nautical miles to the northwest of the Hebrides. Greenpeace
argued that the dumped Spar would do irreparable damage to the
deep-sea ecosystem, possibly with harm to humans, and that it
was in any case wrong to use the deep ocean as a rubbish dump.
After worldwide media coverage, and widespread public protest,
Shell abandoned their deep disposal plan on June 20 to the delight
of Greenpeace and the obvious displeasure of the British Government.
The Government had granted Shell a deep-sea disposal license
on the basis of a Best Practicable Environmental Option study,
supposedly based on subjective scientific evidence without overriding
financial considerations. Government ministers therefore argued
that Shell's capitulation flew in the face of science.
In March 1996, British scientists reported
that the most probable source of CJD responsible for the deaths
of a number of young persons in the last two years had been BSE
in British cattle resulting from the now banned practice of using
feed supplements derived from scrapie infected sheep. The result
was catastrophic "loss of public confidence." The ministers
involved claimed initially that they had and were acting strictly
according to the scientists' advice and that, as a result, British
beef was now totally safe. It didn't work. Our EU partners banned
all imports of British beef products and instructed the UK to
stop exporting them anywhere. In response, the UK Government
announced a major cattle cull that everyone, including the European
Agriculture Commissioner, admits has no scientific basis, but
is simply a gesture to allay the public's fears.
There is a curious link between these two quite
different situations; in both cases the current actions are at
best ignoring the "scientific advice". In one case
the British Government was, and is, critical of Shell's action
because it apparently ran counter to the science; in the other,
the Government's own response, by its own admission, is open to
the same criticism! Where does this leave the role of science
and scientists in these complex risk scenarios? For possible
answers I return to the Brent Spar situation since my knowledge
of BSE and CJD is gleaned from the media, a notoriously unreliable
authority!
Having given up their initial plan, Shell had
the Spar towed to Erfjord in Norway where she still (April 1996)
awaits a decision on her fate. In the meantime, the argument
about whether or not the Spar could, or should, have been dumped
in the deep Atlantic raged in the scientific press and in the
public media. Much of the debate was based on unsubstantiated
claims and counterclaims, for the affair was surrounded by confusion
and misinformation, particularly about the make-up and contents
of the Spar, and how good were the arguments used in the BPEO
study. The first was largely settled in November 1995 when Det
Norske Veritas published its independent inventory of the Spar's
contents, broadly confirming the figures originally provided by
Shell and correcting the erroneous Greenpeace estimates, especially
of the amount of hydrocarbons present. The second was, and is,
more complex and contentious.
The BPEO and associated Impact Hypothesis documents
were based on reports produced by consultants employed by Shell.
These discussed various aspects of the deep oceans in general
and of the sites selected for the possible disposal in particular.
They contained a number of glaring errors and were severely,
and justifiably, criticised by scientists from the Scottish Association
for Marine Science Laboratory at Oban who probably know more than
anyone else about the area chosen as the final dump site. My
own view, that while the chosen dump site was not ideal, the deep
sea disposal of the Spar would not have caused any significant
environmental damage, and certainly less than that which might
result from it being dragged through the shallow North Sea, was
not based on the BPEO documents and was therefore unaffected by
the errors. In other words, I believed that the BPEO investigation
had come to more or less the right answer, but probably for the
wrong reasons.
The apparent disagreements between so-called
experts cast an aura of doubt which led Tim Eggar, the Energy
Minister at the DTI, to ask the Natural Environment Research Council
to set up an independent expert group to look into the decommissioning
of offshore structures in general and specifically to "examine
the scientific evidence in relation to the potential environmental
impacts of large offshore structures, using the Brent Spar as
an example." This group brought together expert deep-sea
biologists, physicists, chemists, geologists and engineers, not
only from the UK but also from France and Germany. Its first
(and possibly last) report, published in late April 1996, avoided
expressing an opinion for or against deep sea dumping. But among
the many conclusions and recommendations there are two which are
particularly relevant. First, the group felt that "..the
public were not convinced that all relevant factors had been taken
into account, or that the best available information had been
used in reaching the decision to proceed with deep sea disposal"
and went on to suggest that "...the present procedures for
the granting of licenses could be improved by adopting a more
open process, with provision for independent review of the scientific
assessment." The Group accordingly recommended that "...revised
procedures should include .... means to ensure that the appropriate
professional advice is used in devising criteria for the choice
of sites, writing site specific survey specifications, ensuring
the quality of the surveys and evaluating the results.."
and "mechanisms to allow consultation with outside bodies
that are well informed about the environmental questions involved,
including international bodies, both at the stage of the development
of the BPEO, and when the survey results are being evaluated."
In this context, whether or not the Brent Spar
should have been dumped in the deep-sea is irrelevant. The much
more important point is that in the final (or at least, latest)
decisionmaking process science was simply disregarded. Does this
matter? I believe it does, otherwise why bother to ask scientific
questions in relation to any 'risk' activity, whether it be disposing
of waste, driving a car, eating beef, smoking or indulging in
any number of other practices that various groups of humans find
necessary or pleasurable. So why was science apparently ignored
in the Brent Spar affair? The short answer is that Shell believed
that the potential commercial damage that would be sustained if
they continued to follow the 'scientific advice' was far greater
than the cost of reversing the decision. But why was the public
reaction, apparently in opposition to the science, so strong?
The reason is surely that 'science' failed to put over a clear
message, whereas Greenpeace, apparently also using science as
a tool, did. So should, and could, anything have been done to
redress this situation, and if so, who should have done what?
I believe there are four broad constituencies
involved; scientists, the government, the environmentalists and
the public, all (except possibly the last) with important responsibilities.
The Scientist
For the sake of this argument, I assume that
"scientists" are independent, at least to the extent
that no-one tells them what their results must be, and that they
are free to respond positively or negatively to requests for information
or advice. I also assume that scientists are honest, that is
that they tell the "truth" as objectively as they are
able.
I believe the first responsibility of the scientist
is to stay within his or her area of expertise. This is not to
suggest that he has to be a world expert on every aspect of a
problem on which he provides information, or even an opinion,
but he must be certain that he has access to, and knowledge of,
the best available data. Failure to follow this policy was undoubtedly
responsible for some of the problems within the Brent Spar case,
at a range of levels. For example, the errors in the BPEO document
should not have been made by anyone with an up-to-date knowledge
of the deep-sea literature. Consequently, the organisations who
accepted the Shell contract should either have refused it, or
should have ensured that they obtained expert advice in those
areas in which their own expertise was not adequate. I do not
believe that the "blame" can be placed on the contractor,
in this case Shell, since they cannot be expected to know who
is or is not expert in a particular area.
A second responsibility for scientists is the
obverse of the first. Thus, if a scientist has specialist knowledge
of a situation or topic, and is aware that a potentially important
decision may be taken on the basis of inadequate or erroneous
information, he has a responsibility to attempt to correct the
error. If this involves going public, for instance via the media,
a third responsibility comes into play, the need to explain scientific
data as clearly and unequivocally as possible. This need not
involve compromising scientific integrity or playing down the
inevitable uncertainties, but simply avoiding the temptation of
all professionals to overuse jargon and to talk down to the uninitiated.
Finally, all scientists have a responsibility
to disseminate their knowledge to a wider public. One good reason
is that most of us receive our funding directly or indirectly
from the public, so that we have no right not to make the results
available to them. But the Brent Spar affair clearly exemplified
a more important reason; the non-scientific public, including
the media, politicians and other policy makers, are appallingly
ignorant of even the most fundamental facts. The reasons for
this corporate ignorance are undoubtedly complex, but scientists
have to accept at least some responsibility. Collectively we
have not and do not communicate well with non-scientists. We
must always be prepared for policy decisions to be taken contrary
to the scientific indications because of an emphasis on financial,
political or emotional factors. But if these non-scientific factors
gain sway because of ignorance of the scientific arguments, we
have only ourselves to blame.
The Government
Politicians, and their associated civil servants,
constantly take complex policy decisions based on a wide range
of disparate factors. As the Shepherd group recognised, in the
case of environmental and public health issues, science is only
one such factor within a complex including social, ethical, aesthetic,
legal and economic ones. There is a potential curious paradox
here. Science is becoming more and more complex and specialised
and I have argued above that individual scientists should avoid
straying outside their area of expertise. In the Brent Spar case
it is unlikely that a single scientist would be qualified to assess
all the possible impacts. Consequently, the choice between complex
scientific options, quite apart from all the non-scientific factors,
is likely to be made by someone with very little knowledge. This
is probably unavoidable, and even desirable, but to enable such
judgements to be made, the available data and scientific expertise
must be adequate. Government has two clear responsibilities in
this area; to ensure first that the relevant information and expertise
exist, and second that it is used overtly in the decision making
process.
The second of these is relatively easy, and
is simply a matter of procedure. The Shepherd group suggested
procedural chances which would have improved matters in the case
of Brent Spar; similar improvements could be introduced in other
areas. But ensuring the existence of the relevant expertise is
more difficult. Government funding for science is decreasing,
while the emphasis on making the funded science relevant to industry,
and even sharing costs, is increasing. Yet industry is rarely
sufficiently far-sighted to see the potential future relevance
of seemingly esoteric science. The deep-sea is a classic case.
Left to industry it is unlikely that we would know anything about
the deep oceans. The existence of scientists able to comment
with authority on the possible impacts of the deep-sea disposal
of the Spar was entirely due to the past history of Government
support for 'pure' oceanography. It is government's responsibility
to ensure that this will be true, and not just for marine science,
in 20, 50 or 100 years time; science at this level left to industry
will not be "safe in their hands."
The Environmentalists
Pressure groups such as Greenpeace have clear
objectives and, understandably, use all the cards in their hand
to further their case; they are obviously very good at it. But
they owe it to the public, to their supporters, and even to their
cause to be scientifically 'honest'. I am not referring here
to their erroneous claims about the Brent Spar's contents; this
was simply a mistake, and they readily admitted it. Nor am I
referring to their failure to correct the widespread misunderstanding,
in the early days, that the Spar was to be dumped in the North
Sea. The 'honesty' I believe they should show is much more subtle.
They believe, sincerely I am sure, that nothing should be dumped
in the oceans, deep or shallow, as a matter of principle, or what
I prefer to call dogma. Consequently, at least some Greenpeace
supporters will admit in private that a dumped Brent Spar would
not have had a significant impact and they were accordingly able
to dismiss the revelation of their over-estimate of the hydrocarbon
content as irrelevant. But the public were not told this; instead
they were fed a frightening diet of radioactivity, heavy metals,
oil and PCBs. This is the sort of subtle dishonesty that I believe
does the so-called environmental lobby no credit.
The Public
It would be inappropriate to attribute responsibility,
in the sense I have used it here, to that nebulous concept "the
public". But whatever else it did, the Brent Spar affair
showed Joe and Joanna Public that, collectively, they have enormous
power. In exercising that power, I would simply suggest that
they listen carefully to all the arguments, and particularly the
scientific ones. Look for, and insist upon, clear statements:
but beware of anyone who has pat answers to all the questions;
life just aint like that. Finally, remember that the nice guy
isn't necessarily right. Just occasionally, political and industrial
Goliaths take the right decision, though possibly for the wrong
reasons.