PRACTICING PRECAUTION and ADAPTIVE MANAGEMENT ...

effects of decisions are systematically compared with observed effects as determined frommonitoring or surveillance; (8) large discrepancies between observed and predicted effects ofpast decisions reduce the likelihood that the same decision will be made in future.Unlike the case of precaution, the degree of semantic congruence assigned to a particularadaptive management element depends on whether one considers “knowledge” and “pastdecisions” to refer to knowledge and past decisions of PMRA only (internal knowledge anddecision-making) versus scientific knowledge and/or past decisions generated by institutionsother than PMRA (external knowledge and decisions). Under the former interpretation, elements(2) and (4) – (8) by definition apply only to re-evaluations, so that registrations can be evaluatedonly with respect to elements (1) and (3). Under the latter interpretation (i.e. where “pastdecisions” may be previous decisions by PMRA or another regulatory agency), elements (1) and(3) – (8) apply to both registrations and re-evaluations, and only element (2) is not applicable tothe former. We use this interpretation here.The results of the analysis are striking (Fig. 2). First, in no instance was there anyindication that PMRA decisions were treated as a scientific experiment, in the sense describedabove (Fig. 2a, b). Secondly, for all other elements with the exception of element (3), bothregistration and re-evaluation decisions scored poorly. The intermediate average score (andlarge variance) for element (2) reflects two different subpopulations in the sample. First, underboth PCPA (1985) and PCPA (2002), all re-evaluations (either discretionary or required) aresupposed to take into account two issues: (1) new information, acquired since the originalregistration, on the health or environmental impacts of the product in question (or its value); and(2) changes in “risk” tolerance, i.e. changing societal views on what constitutes an “acceptable”risk. So when little or no new information adjudged relevant to the re-evaluation process isadduced by the registrant, and there is no “reasonable cause” to believe that the product poses anunacceptable risk, the original registration decision is implicitly considered to have been correct.Such decisions score highly with respect to element (2). On the other hand, the sample alsoincludes re-evaluations of products for which there was reasonable cause to believe that theoriginal decision may not be currently appropriate, either because new information does suggestthat the product indeed poses unacceptable risks (perhaps as used originally) or because societalstandards have changed. These decisions score poorly with respect to element (2). – the result isan overall intermediate score and large within-group variance (Fig. 2b).4.04.0Semantic congruence score3.53.02.52.01.51.00.5(a)3.53.02.52.01.51.00.5(b)0.01 2 3 4 5 6 7 80.01 2 3 4 5 6 7 8Precautionary elementPrecautionary elementFig. 2. Average (+/- 1 standard error) semantic congruence scores for various adaptivemanagement for registrations (a) and re-evaluations (b). For further explanation, see textand Appendix ii.C. Scott Findlay & Annik Déziel – Potentially Practicing Precaution: Canadian Pesticide D-80Regulation and the Pest Regulation Management Agency