Chemicals and Witches: Standards of Evidence in Regulation
Arousing Public Fear Is an Ancient Bureaucratic Strategy
MARCH 01, 1995 by ROBERT H. NELSON
Dr. Nelson is Professor of Environmental Policy at the School of Public Affairs at the University of Maryland.
Why do bad things happen? Why does a child die? Judeo-Christian theology instructs its followers to trust that God has a purpose, however difficult it may be to understand.
That answer has not been fully satisfactory for many people. Before the Enlightenment, many in the European religious world explained disasters through evil spirits, witches, and other agents of the devil, which undermined true faith, spread injury and disease, and caused many bad things to happen.
Our modern and scientific age—a time when most people no longer believe in the active presence of the devil in the world—confronts a similar problem. Science tells us that our fate is a matter of the workings of the laws of nature: Cancer is an accident of cell biology; a high death rate in one town is simply the random statistical consequence of the workings of probabilities in a nation with many thousands of communities. Yet secular thought today is as filled with devils, and bad things are as attributed to evil influences, as in the European world of 500 years ago.
The many parallels were developed in a remarkable article—still known mainly to environmental specialists—that appeared in 1980 on “Witches, Floods and Wonder Drugs.” The author, William C. Clark, then at a prestigious international think tank, the International Institute for Applied Systems Analysis in Vienna, Austria, is today a member of the science, technology, and public policy program at the Kennedy School of Government at Harvard University.
Clark begins by noting that “for several centuries spanning the Renaissance and Reformation, societal risk assessment meant witch hunting.” Indeed, people found in “`witches’ a convenient label for their fears of the unknown.” It was their way of dealing with “the inevitable misfortunes which befell one’s crops, health and happiness.” Although the Catholic Church did not aggressively persecute witches for many centuries, the publication in 1486 of The Hammer of the Witches proved, as Clark writes, a “collective consciousness watershed.” Witch hunting rose to fever pitch in the sixteenth and seventeenth centuries, as public panics came and went, and many tens of thousands of alleged witches were executed throughout Europe.
Witches and Chemicals
Clark sees similar phenomena underlying our modern chemical panics, although the hapless victims are no longer executed; instead, they lose their jobs, businesses, and communities. The governing authorities today are often just as craven in capitulating to public fears.
He notes that a key question is “the kind of evidence we admit in our attempts to answer” questions of cause and effect, of guilt and innocence. In both witch hunting and contemporary chemical hunting, there is no “conceivable empirical observation which could logically force an answer `No.’ In neither case is there a `stopping rule’ which can logically terminate the investigation short of a revelation of guilt.”
In the witch hunts of the sixteenth and seventeenth centuries, “the Inquisition’s principal tool for identifying witches was torture. . . . If she said no, what else would you expect of a witch? So she was tortured until she confessed the truth.” And in our current chemical inquisitions, Clark notes, something that is not a risk with a parts-per-trillion test “can always be exposed to a parts-per-billion examination. . . . The only stopping rule is discovery of the sought-for effect, or exhaustion of the investigator (or his funds).”
Environmental investigators, for example, proclaimed a decade ago that dioxin was among the most carcinogenic chemicals ever seen. The occupants of Times Beach, Missouri, were relocated in haste after dioxin was found in its streets. Yet, by the 1990s, the scientist who had called for this evacuation had recanted. Workers heavily exposed to dioxin in a 1970s industrial accident in Italy were showing few of the dire effects predicted. Michael Gough, formerly director of the Center for Risk Management at Resources for the Future, and past coordinator of a major dioxin study for the Congressional Office of Technology Assessment, wrote in 1993 that all credible studies “have concluded that dioxin exposure has not caused elevated levels of cancer.”
In response to such challenges, the Environmental Protection Agency initiated a new dioxin study in 1991. Yet when the EPA finally released its study in 1994, dioxin was not exonerated. The EPA grudgingly acknowledged that the original cancer concerns might still be unproven by any direct epidemiological evidence, but now dioxin was charged with a new litany of sins. It was as Gough had commented: “No experiment or study can prove the negative. . . . As each postulated connection dissolves, new ones can be proposed.”
Perhaps dioxin will eventually be proven a great menace. The full scientific truth will not be known for some time to come. What is obvious is that, like the witch hunters of the sixteenth and seventeenth centuries, the members of government bureaucracies have a large personal stake in the outcome—as large as the chemical manufacturers whose scientific reports are routinely dismissed by many people. As Clark noted, “there was certainly an element of opportunistic careerism in the Inquisition, and there is almost certainly an element of opportunistic careerism in the present risk assessment movement.”
Arousing public fears is an ancient bureaucratic strategy, practiced effectively early in this century, for example, by the founder of the Forest Service, Gifford Pinchot. He warned constantly—and altogether baselessly, as matters turned out—that the nation would soon run out of wood, that there would be a dire “timber famine.”
Witch hunting was not limited to any one religion or country. Indeed, while the Inquisition was Roman Catholic, about 4,000 witches were executed in Calvinist Scotland between 1590 and 1680. Paul Johnson reports in his History of Christianity that “wherever Calvinism became strong, witches were systematically hunted.”
The Salem Experience
The execution of 19 witches in Salem in 1692, backed by leading members of the Massachusetts Puritan branch of Calvinism, was no great anomaly, although it came near the close of the witch hunting craze. The Salem court that heard the case consisted of seven prominent citizens, including the lieutenant governor of the Massachusetts colony. The victims were convicted largely by “spectral” evidence supplemented by the confessions of other supposed witches. Spectral evidence consisted of testimony in which a vision of the alleged witch—the “spectre”—was said to have appeared before the witness and tempted that person to evil deeds. The appearance of such a spectre was attributed by the court to the witch, and was considered to be decisive evidence of the possession of witchcraft powers.
(By the way, no one who confessed was executed at Salem. Execution was reserved for people who refused to admit their guilt and thus continued in defiance of God and the court—hardly an incentive to resist confession.)
Today, risks of chemicals are assessed from animal tests based on the “maximum tolerable dose.” A sample of rats, for example, will be exposed to the chemical at the highest dose that the rats can accept and still continue to live. This dose will often be many hundreds or thousands of times the equivalent doses to which humans are exposed. If the rats then show abnormal rates of cancer or other health problems, the chemical stands convicted.
The standard of proof here is not much higher than the spectral evidence and the “voluntary” confessions accepted by the Salem court. Normal human health requires many chemicals that would be very harmful in the body at much higher concentrations. There are large numbers of “natural” chemicals that have been present in the food supply for thousands of years and that today show positive carcinogenic results under current testing methods.
Science magazine found the existing standards of scientific evidence so lacking that it called editorially in 1990 for an end to chemical witch hunting: “Resultant stringent regulations and attendant frightening publicity have led to public anxiety and chemophobia,” said the editorial. “If current ill-based regulatory levels continue to be imposed, the cost of cleaning up phantom hazards will be in the hundreds of billions of dollars with minimal benefit to human health. In the meantime, real hazards are not receiving adequate attention.”
Bruce Ames, an early developer of tests for carcinogenic impact and Professor of Biochemistry and Molecular Biology at the University of California at Berkeley as well as a member of the National Academy of Sciences, writes with Lois Gold that existing maximum tolerable dose methods of testing, even though they are a main method used by the government for assessing cancer risk, are of little worth. They “cannot predict the cancer risk to humans at the much lower levels to which [humans] are typically exposed.”
The Massachusetts executions of witches came to an end when charges started being hurled not only against the social outcasts and the poor but against the governing officials, the relatives of clergy, and other prominent members of the Massachusetts colony. The turning point was a public statement issued in the fall of 1692 by Increase Mather and other leading Puritan ministers rejecting the use of spectral evidence. Similarly, Clark reports that a critical event in the winding down of the witch trials in Europe was the publication by Inquisitor Alonso Salazar y Fras of a detailed analysis of witch burnings at Logroño, Navarre. The analysis by this well-respected member of the church showed that “most of the original accusations had been false, that torture had created witches where none existed, and that there was not a single case of actual witchcraft to show for all the preaching, hunting, and burning which had been carried out in the name of the church.” Perhaps Bruce Ames and the small band of other scientists who have had the courage in recent years to insist on firm evidence in the face of today’s environmental panics will eventually find a similar place in history.
Environmentalists as Puritans
Environmental witch hunting is only one of several ways in which the more radical segments of the present environmental movement have revived the seventeenth-century heritage of Puritan Massachusetts. When radical environmentalists such as David Brower and David Foreman refer to mankind as the “cancer” or “AIDS” of the earth, they are repeating once again the old Calvinist message of doom and gloom—that mankind has fallen into a deep and fundamental state of depravity and that the earth is headed for divine retribution unless human beings mend their corrupt ways.
In his classic study of the New England mind of the seventeenth century, the Harvard historian Perry Miller observed that the Puritans were “obsessed with” the “theology of nature.” They had a “reverence” for nature reflecting their belief that “the creatures . . . are subordinate arguments and testimonies of the most wise God, pages of the book of nature, ministers and apostles of God, the vehicles and the way by which we are carried to God.” Environmentalism today, in essence, secularizes this theology.
In Nature it is possible to experience directly the Creation; in theological terms, it is possible to encounter a work of God free of the corruptions introduced by sinful humanity. Indeed, intellectual historians such as Miller have traced a path from the Puritans through the New England transcendentalists of the nineteenth century to current environmentalism. The founder of the Sierra Club, John Muir, followed in the footsteps of Ralph Waldo Emerson; the late Edward Abbey, a writer who lamented the loss of the pristine West, was an intellectual descendant of Henry David Thoreau.
The Judeo-Christian heritage is the bearer of many of the glories of Western civilization. American Puritanism helped to spur abolitionism and women’s rights, and is the great source of much of the reform impetus in American history. Yet Western religion has also fallen into moments of persecution and fanaticism.
Such moments come when trust in reason erodes. The persecution of witches arose at about the same time as the Protestant Reformation. The Roman Catholic church became increasingly defensive as Luther, Calvin, and other Protestants contested its authority. Reason was called into question as the Reformation challenged the natural law theology of the medieval Roman Catholic church. Similarly today, trust in reason is fading as science faces growing numbers of doubters. This paves the way for hysterical reactions.
As environmentalism undertakes the worthy task of further developing the religious grounds for the stewardship of the earth, it will be well to recall these lessons of the past. In matters of environmental regulation of chemicals, the future credibility of the environmental movement rests on demanding strict standards of proof before taking actions that displace many people and spend many tens of billions of hard-earned citizen dollars. 
1. William C. Clark, “Witches, Floods, and Wonder Drugs,” in Societal Risk Assessment: How Safe is Safe Enough? edited by Richard C. Schwing and Walter A. Albers, Jr. (New York: Plenum Press, 1980), pp. 287-313.
2. Michael Gough, “Dioxin, Perceptions, Estimates, and Measures,” in Kenneth R. Foster, David E. Bernstein, and Peter Huber, eds., Phantom Risk: Scientific Interference and the Law (Cambridge, Mass.: MIT Press, 1993), p. 268.
7. See Robert H. Nelson, “Environmental Calvinism: The Judeo-Christian Roots of Eco-Theology,” in Roger E. Meiners and Bruce Yandle, eds., Taking the Environment Seriously (Lanham, Md.: Rowman and Littlefield Publishers, Inc., 1993).