Manufacturing improves our quality of life by providing goods and services, to satisfy the needs of Australian people, but manufacturing operations may affect the environment.

Sustainable balance between Development of and Conservation of our natural (and other) resources is required, so that industry can operate confidently in an informed, realistic and environmentally sound manner. Decisions on environment, development and conservation practices must take full account of economic, social and technical implications (of action or inaction). Rigorous inquiry, factual information, wide-ranging community consultation is needed, to provide the basis for identifying any "trade-offs" and for making consistent, sound and transparent decisions.

Manufacturing industry has accepted the task of identifying efficient paths to improved environmental management. Awareness of the overall environmental effects of products;an outlook of stewardship for whole of product life; greater Government collaboration in economically efficient waste disposal, recycling or minimisation; practical guidelines on restoration, decontam-

ination, decommissioning and reuse of sites; all these will form part of the framework for allowing each business to achieve responsible environmental management.

ACM SUPPORTS ESD AND CAUTION

The draft National Strategy for Ecologically Sustainable Development (November 1991) p.159 states that we should "deal cautiously with risk and uncertainty, particularly as we deal with new products and processes and with the implications of new technologies and where there is a lack of information about environmental impacts" ACM supports this general principle of prudence and recognises the validity of extension to cover concerns for other items on that page: biodiversity, inter- and intragenerational equity, global issues.

Environmental Policy Principle 3.5.1 of the Intergovernmental Agreement on the Environment (IGAE) (March 1992) states that;

"In the application of the precautionary principle, public and private decisions should be guided by:

1. careful evaluation to avoid, wherever practicable, serious or irreversible damage to the environment and
2. an assessment of the risk weighted consequences of various options."

This segment of the IGAE follows those phrases acknowledging the need for integration of environmental economic considerations. The primary aim is to improve community well-

being. We should exercise caution in making our decisions, but decisions must be made.

ACM concurs with the IGAE's first principle of environmental policy that development and implementation of environmental policy and programs should be guided by the same considerations and principles at all levels of Government.

THE PRECAUTIONARY PROBLEM

Manufacturing industry provides goods and services to satisfy community demands and improve community well-being. Manufacturing, government and the broader community aim to benefit the future: for their shareholders, their constituents, their children. These groups are not discrete or mutually exclusive, and modern environmental management seeks to engage them all in deciding on environmental issues.

The Brundtland Commission Report ("Our Common Future, 1987) wrote of the need for a new approach, called "anticipate and prevent". Sustainable Development requires an anticipatory approach to environmental policy. Good anticipation requires good information. Good information requires good research. Good research may take time.

Some would use that time as a delay on any action, i.e. halt any development until complete scientific certainty was achieved, to allow perfect "anticipation". This absolutist stance shifts the burden of proof to always give the environment the benefit of any doubt. Shifting the onus of proof to require that a proponent for any development must absolutely disprove any objector's claim, no matter how extreme or unfounded, is clearly illogical, can waste resources, and can deny benefits to the community.

Rather than settle for inaction wherever there is any doubt, ACM would prefer to actively engage in the integration of environmental, economic and social issues, using the National ESD Strategy and IGAE principles to identify areas to improve community wellbeing, then applying the full measure of scientific knowledge (conditioned by our current awareness of risks, consequences and uncertainties), to generate optimum decisionmaking.

PRECAUTION IN PRACTICE

Prudent decision-making, derived from "no-regrets" policies, can in some cases offer an almost risk-free and cost-effective approach to environmental management. Global greenhouse warming is an example of an issue whose causes, effects, costs and benefits are still only partly understood. However, many measures to reduce emissions simply revolve around increased efficiency of resource use. These "no-regrets" measures, such as energy and waste reductions, have been part of responsible environmental management, and make sound economic sense also.

Actions such as energy or waste reduction, materials recycling or odour and noise minimisation will only be as effective as the chosen technology. New plants can usually be expected to install the latest cost-effective environmental protection. BAT, in special situations, may be necessary, but will often come at a high price.

ACM supports and promotes, to Its manufacturer members, Best Practice Environmental Management (BPEM). This calls for a systematic approach with an "environmentally inclusive" attitude built, ideally, around a comprehensive environmental plan.

Past practices often gave insufficient weighting to environmental externalities, but industry recognises and welcomes the opportunity to participate in formulation of appropriate modern standards. The first of the 7 goals in BPEM is a change in Style, from the older paradigm which lauded "efficiency" to the new BPEM paradigm of "excellence".

Caution is already part of everyday operation of many manufacturing plants, and no plant which strives for an outlook of environmental excellence will be able to avoid incorporating caution in decision-making. A positive anticipatory attitude of caution will allow an optimal balance, and will reflect the uncertainties and variability associated with natural systems.

CRITICISM OF AN EXTREME PRECAUTIONARY PRINCIPLE

A "precautionary principle" is a vague general approach to environmental issues. It cannot be a regulatory norm because how much caution is a political/social decision. Delaying action in the hope that new information will resolve, or reduce, uncertainty is itself a decision. (The Regulator's dilemma).

In many circumstances, the choice is not between risk and caution, but between one risk and another, e.g. a decision not to chlorinate water supplies because of excessive caution about use of chlorine may expose citizens to an increased risk of infection, or a decision not to build an unpopular freeway may increase exhaust emissions by slowing the passage of through traffic.

Several of today's most serious environmental problems were entirely unanticipated. There was considerable scientific certainty that CFCs and DDT were environmentally benign, but scientists had not tested for the right impacts:

DDT - was tested for toxicity. The problem of biomagnification was not foreseen.

CFCs - their persistence and stability were originally thought to be their prime features, minimise their environmental impacts. The problem of damage to stratospheric ozone was not foreseen.

The very simplistic form, advocated by some, of "precautionary principle" is that of "eliminating and preventing the release of substances, especially synthetic and persistent substances, whether there is reason to believe that damage or harmful effects will be caused, even where there is inadequate or inconclusive scientific evidence to prove a causal link between emissions and effects". (Greenpeace Submission to 13th Meeting of London Dumping Convention Scientific Group on Dumping).

Clearly, this would prohibit almost all human activity. The expressions "reason to believe", "damage" or "harmful effects" allow free conjecture by objectors. The word "synthetic" is value laden but scientifically confusing. An objector is not required to provide any evidence to support his conjecture about environmental "harm". And there is no recognition that other factors may be more significant, i.e. sometimes we may have to accept the reality of some effect on our environment, in return for social, economic or other benefits.

CONCLUSION

A realistic "precautionary principle" is merely one component of a suite of complementary approaches to environmental management. "Full scientific certainty" is difficult, perhaps impossible. But rigorous assessment of risk and uncertainty, accompanied by valuation and comparison of costs and benefits of development and conservation, is an essential part of the effective integration of economic, social and ecological management which must underpin a sustainable and equitable approach to inter - and intragenerational equity.

ACM and manufacturers will continue to aim for Best Practice Environmental Management, with its in-built philosophy of moving towards excellence. Where possible, "no regrets" activities may buy time to improve knowledge.

Caution, followed by informed decision-making rather than a "precautionary principle" which prohibits action, is the realistic path to employ in most aspects of human endeavour, to achieve the most cost-effective outcomes and benefits for humans and for their natural environment.

Manufacturers at this conference will look forward to learning how the application of a realistic version of a precautionary principle can assist in good environmental management, which is becoming an integral part of every industry's operations.

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