Cancer Warnings: How Justified Are They?

What happens when the skull and crossbones goes on a product? In the case of cancer warnings, the consequences can be severe. If the label contains the term "lung carcinogen", you might expect to compensate a lot of smokers, meet a lot of expensive lawyers, be counseled by equally expensive consultants and pay sharply elevated insurance premiums, if you are able to obtain coverage at all. At the extreme, you may face plant shutdowns, job losses or even Chapter 11 bankruptcy. Regardless of how you fare, you are likely to learn some very disconcerting things about the risk evaluation and regulatory system which required you to label in the first place. If a particular material or product does pose a health risk, you are obliged both legally and morally to warn those potentially exposed. Once that warning appears on the label, however, the consequences are often beyond your control. You and your embattled product become part of a legal/regulatory system which has a life of its own. Therefore, the issue of health labeling is not so much whether one warns but rather whether the warning itself is justified and the reasonableness of what happens afterwards. It is this matter of justification and reasonableness, particularly of cancer warnings, which this paper addresses. Until, as they say, your ox has been gored, we tend to believe that risk is determined by the best available technology and expertise We expect that risk evaluators appreciate the ramifications of their work and place things in proper perspective; that risk has been appropriately demonstrated before it is publicized and regulated; that the time-honored concept of prudence, to err on the side of safety, has not been excessively stretched. Unfortunately, the risk evaluation process is rarely, if ever, this