Umicore’s position on VODO paper
On 8 October 2009 a document entitled “Environmental justice/ecological debt: the case of UMICORE in Hoboken (Belgium)” was published by the Flemish Platform for Sustainable Development (VODO) (available on: http://www.ceecec.net/case-studies/ecological-debt-environmental-justice-in-belgium/). The author, Nick Meynen, is a free-lance journalist with a background in geography.
Whilst the paper praises Umicore’s track record of cleaning up historic soil pollution and cutting emissions, it also claims to have calculated an external public health cost of historic metal emissions by Umicore’s Hoboken site in Belgium. Umicore has carefully reviewed the merits of this document and has found the non-scientific methodology and the use of statistical data (most of which has been in the public domain for many years) to be flawed and inadequate. The conclusions of the document are invalidated by these methodological flaws and compounded by a series of factual errors.
Fundamental methodological flaws
The author’s main assertion – that there is unique causality between Umicore’s Hoboken activities and cases of cancer in the Hoboken area – has no basis in sound science or scientific protocols. The author himself acknowledges that he draws conclusions “without pretending to be precise, [n]or complete” and that the key data he uses have not been adjusted for “the many possible interfering factors such as age, smokers and other living habits”. However, the author then goes ahead to conclude that “we do know from a detailed, but unpublished and unconfirmed, study based on patients’ records that there is a clear positive correlation between cancers and proximity to the factory”. It is not possible to arrive at such conclusions using such an incomplete approach and using separate and unlinked data. Furthermore the author provides no information on the cohorts that have been included in the evaluation and little or no information regarding the specific calculation methods used to arrive at his conclusions.
“Post-normal science” and “popular epidemiology”
The paper relies on non-scientific concepts (which the author describes as ”post-normal” science and “popular epidemiology”). According to its advocates, post-Normal Science is a concept to deal with problems in which “facts are uncertain, values in dispute, stakes high and decisions urgent. For these new problems science usually cannot provide well-founded theories, based on experiments, for explanation and prediction”.
Critics of this approach to science, which does away with peer reviews, the logic of scientific discovery and the existence of objective facts, have labeled it “The Flight from Science and Reason” (Annals of the New York Academy of Sciences) or “Higher Superstition”. Some critics also consider post-normal science an attempt to ignore proper scientific methods for political ends.
“Popular epidemiology” is a process whereby “laypersons gather scientific data and other information and also direct and marshal the knowledge and resources of experts. “
The author’s conclusions are negated by the use of a non-science based methodology. The author implies, that his use of a “post-normal” approach allows him to avoid adhering to scientific methodologies, protocols and accuracy.
Ecological debt
The author also puts forward various views on societal and environmental costs (and historical ecological debt): this involves a wider societal issue that cannot be addressed by a single company or even a single industry. In any case, Umicore is already applying environmental standards that, in many instances, go well beyond the demands of any legal framework. The issue of historical ecological debt and the internalisation of social and environmental costs encompass a whole range of actors from nation states, supra-national bodies (such as the EU) and industry. Attempting to single out single entities in a non-scientific way runs counter to this need.
The authorities (both at European and national level) are addressing the issue and have already implemented certain measures to internalise external costs. The European Union in 2004, for example, adopted a directive on environmental liability with regard to the prevention and remediation of environmental damage. It established a framework based on the "polluter pays" principle, according to which the polluter pays when environmental damage occurs. The directive went into force in Flanders in 2008.
A pioneer in remediation
Umicore has been a pioneer in its undertaking to face up to the challenge of historical environmental pollution around its sites in Flanders and elsewhere. This has been done based on sound scientific evidence and consistent data. The covenant signed with the Flemish authorities in 2004 was a landmark step in this regard. Together with the authorities Umicore has made significant progress towards completing the remediation of those areas around those sites where soil and groundwater was demonstrated to have been polluted by industrial activities that date back many years.