It’s time to share a bit more my experiences from talking to colleagues here in the US. One issue that comes up again and again is how Europe and the US are approaching risk, for example related to new technologies. In Europe, I often heard comments like “If Europeans weren’t so risk-averse, Europe would be much more competitive” or “The Americans have a much more risk-taking attitude than we have”. But is this true?
My first observation is that we should be careful with generalized statements. The US can be incredibly risk-averse, e.g. when it comes to stem cell research, while Europe can be seen as very risk-taking – take for instance the multi-billion Euro investment in the Large Hadron Collider at CERN in Geneva. In fact, you cannot even talk about “the US” and “Europe”. If you look closely, both Europe and the US are incredibly fragmented if you study the approach taken towards any given technology in any State or Member State.
To explain myself: Make a map of the pro- and anti-GMO countries in Europe. Put next to it a map of pro- and anti-nuclear countries. Put next to it a map of pro- and anti-fracking countries. They will all look different. And the result cannot be explained with just North vs. South or Catholic vs. Protestant. Then make the same exercise with the US. Again, you will get very patchy maps and they seem to have nothing to do with coast vs. interior or Bible Belt vs. not Bible Belt. In fact, issues that are discussed very controversially in Europe, are also discussed very controversially in the US, fracking being one example. The debates have different connotations perhaps – the religious aspect being more prominent in the US – but in essence we are discussing the same issues.
The reasons why certain countries or even parts of countries (see England vs. Scotland on GMOs!) approve or reject a technology lies much deeper. Culture and/or religion certainly have an impact (take the relationship of French people to food), but often it boils down to socio-economic stakes. This explains for instance why Poland with its big shale gas resources is very happy with fracking while it rejects GMOs. The national media landscape has a role to play (Austria is a typical example, where public opinion is largely influenced by tabloid newspapers), but also institutional set-ups and political traditions matter.
However, and I am aware of the risk of generalizing here, there are differences between Europe and the US. They are essentially rooted in what I would call “the myths on which our nations are built”. The US is still very much coined by the “Go West” spirit of its founding fathers and mothers. Explore the unknown, be fruitful and multiply, don’t ask what the country can do for you, but what you can do for your country. In such a spirit taking risk is rewarded more easily than in Europe where nations carry around rucksacks filled with thousands of years of history with an implicit tendency of “we have always done it like this”.
This does not mean that either side is more or less willing to take risks, but that in my view the effort to overcome the initial “societal inertia of mass” is higher in Europe than in the US. It’s the same inertia that stops many European SMEs from becoming quickly global players like Facebook, Twitter or Google. In Europe we rather tend to trust companies that have been around for hundred or more years (which does not necessarily mean that they deserve this trust). Would Bill Gates and Steve Jobs have founded their companies in European garages? Probably not because European garages are for parking cars and not for starting world revolutions. In the US, if you haven’t gone bankrupt at least twice you are not even considered an entrepreneur, while in Europe after the first bankruptcy you will have difficulties to find anybody lending you money again (I am exaggerating here to make my point). Again, this has regional variations and the entrepreneurial spirit is likely to be higher in, say, Milan or Turin than in Rome or Naples, due to a number of reasons. Again, I am not talking here about taking more or less risk, but about the societal recognition we give to the one taking the risk, which in my view on average is higher in the US than in Europe, despite the regional differences.
Such underlying philosophies have their impact on institutions and political processes. Essentially, in the US if there is a new technology coming on the market the relevant authority will assess whether it is safe or not. If it is determined safe, politicians will debate whether they want it or not. In Europe things are a bit more messy, as the political discussion will already start at the “Is it safe?” level, inevitably messing up science with politics. This has also something to do with the trust we put in institutions, be they public or private. Again, this is an issue where I notice EU/US differences.
This does not mean that decisions in the US are more evidence-based than in Europe, though. When bringing my kids to school in Boulder I am always amazed to see all the measures in place to ensure a safe way to school for the kids (flashing lights indicating that cars need to go slower in school areas, no passing of school buses allowed when these are stopping etc.), while it is perfectly normal to see the kids rushing around on their bikes after nightfall without any lights or protective helmets on, and I am not even talking here about kids having access to guns stored in their parents’ homes. The selective perception of risk in the US certainly does not follow any logic and is not much different than in Europe. So don’t think that the American approach to things is any more rational than the European one. After all, we are humans and not vulcans!
As in Europe, also in the US there are many factors influencing political decisions and science is just one of them. This leads sometimes to political decisions being very evidence-based, and sometimes to policies going against the evidence. If policies would be based on evidence only, gun laws in the US would look different. German autobahns would have a speed limit. Chinese would have different air pollution laws. And we all know that coffee, if invented today, would never be authorized both in Europe and the US because caffeine is quite a nasty psychoactive chemical. I could give many more examples. But life is not like this and we have to acknowledge that the societal acceptability of issues and, hence, legislation does not always follow the evidence (after all, we are not dominated by scientists!).
However, one result of the above are different standards and thresholds in legislation as evidence is interpreted differently or sometimes ignored altogether. This has the potential to hamper international trade. Those protesting in Europe against the Trans-Atlantic Trade and Investment Partnership (TTIP) often voice their concern that TTIP would allow the “tough” European standards to be lowered to the supposedly weaker US standards. Apart from the fact that nobody has this intention, it is simply not true that the European standards are always tougher. In some areas they are, in others not. Europe is tougher on GMOs, hormones in beef, pesticides and greenhouse gas emissions, the US is tougher on air, water and soil pollution, food colouring, smoking and terrorism. Public authorities in the US are, by the way, tougher in prosecuting ethical misbehaviour of car manufacturers or international sports associations than their European counterparts.
This leads us inevitably to the icon of international trade, the chlorinated chicken. Both, Americans and Europeans are committed to maximum food safety. Americans clean the chicken in chlorine to get rid of all germs. It’s a safe – but not perfect – method and the food is safe to eat. Europeans prefer to treat their chicken with antibiotics to solve the germ problem. This is also a safe – but not perfect – method and the food is safe to eat (although it has an undesired side-effect, namely antibiotic resistance). Both methods are perfectly valid from a scientific point of view. What is different is the philosophy: Americans want that the product is safe when it lands on the plate (ex-post control), while Europeans are rather worried about how it gets there (ex-ante control). Both approaches are OK. Which one to choose is a political question, not a scientific one.
For further reading I recommend the study “The reality of precaution – Comparing risk regulation in the US and Europe”, published by the Delors Institute last year.