Lowering exposures without considering biology and tradeoffs is not precautionary

Both regulations and toxic tort decisions, being guided by an antiquated Precautionary Principle, routinely seek to lower exposure to potential hazards as low as possible. In most cases, these policies ignore key scientific developments over the past several decades finding endogenous production of toxins and the plethora of adaptive mechanisms that affect health and disease processes, including hormetic properties. EPA's risk assessment policy, for example, has explicitly excluded "effects that appear to be adaptive, non-adverse or beneficial." In addition, because of countervailing risks that are often not considered, overall risk increases may be the result of precautionary policies. Increases in risk may be the overall result when we are trying to protect a hypothetical subpopulation but ignoring other affected subpopulations. The linear no-threshold dose-response theory for carcinogens is an important example of low-dose decision making that may be causing the most overall harm. This paper examines the history of how this became a default position and how different trade-offs that are often not practiced result in potential harm to populations not considered in both regulatory and toxic tort decisions.