Health as if everybody counted blog

Toronto’s Department of Public Health, a leader in such areas as publicizing the conflict between eating a healthy diet and keeping a roof over your head when living on a low income, has issued a new report with important recommendations for improving health by promoting walking and cycling.

Among the recommendations: reducing speed limits to 30 km/h on residential streets and 40 km/h on most others, and installing “leading pedestrian signals” at major intersections.  (These are signals that give pedestrians a walk signal a few seconds before the light turns green for vehicle traffic, improving drivers’ ability to seen them.)  The report also notes the need for more investments in pedestrian and cycling infrastructure, and for working with Metrolinx (the regional public transportation authority, now facing drastic funding shortfalls as a consequence of provincial austerity measures) to promote active transportation.

The report is based on a longer study that undertook an extensive review of the evidence on active transportation and health, emphasizing the equity dimension.  It noted, in particular, that “low-income families often live in high-rise neighbourhoods in Toronto’s suburbs,” which are hostile to pedestrians and cyclists.  Roads are wide; marked pedestrian crossings few and far between; pedestrian collisions are more frequent even though pedestrian volumes are lower; and three-quarters of parents do not feel comfortable letting their children walk unaccompanied in their neghbourhoods.

Photo: Richard Drdul,
reproduced under a Creative Commons licenceThe longer study also argued for traffic calming strategies: engineering measures to slow down traffic, like speed bumps and curb extensions, which have resulted in major reductions in injuries and fatalities when implemented in Europe.  A more extensive review of traffic calming and health was published late last year by Canada’s National Collaborating Centre for Healthy Public Policy, and will be the topic of a CHNET-Works Fireside Chat on May 10.
 
Predictably, the Toronto Public Health recommendations were greeted with howls of outrage from some of Toronto’s more retrograde politicians, but as readers of a previous posting (and the longer Toronto study) will know, such measures are either already in place or under serious consideration in many European cities.  This is, literally, an issue of street-level politics: will the “right to the city,” in Henri Lefebvre’s frequently cited phrase, favour pedestrians and cyclists or people protected by two tons of steel and airbags?  In many other Canadian cities, we’re still waiting for Toronto-style public health leadership.

Many readers of the federal budget will have missed the decision to shut down the National Council of Welfare, a small and independent-minded unit of the Government of Canada that since 1962 has been a source of information about the extent and depth of poverty and inadequate social provision in Canada. With its demise, a resource for advocacy on social determinants of health has been lost. It is still possible to use the Council's site to access an interactive map showing that (for example) inflation-adjusted social assistance incomes in Ontario are no higher than they were in 1986. And the ground-breaking 2011 study on The Dollars and Sense of Solving Poverty is still available. To quote just one provocative finding from its summary: "The poverty gap in Canada in 2007—the money it would have taken to bring everyone just over the poverty line—was $12.3 billion. The total cost of poverty that year was double or more using the most cautious estimates," although these are admittedly incomplete and fragmentary. The public health community would be well advised to act fast and download the Council's publications before they are consigned to the memory hole.

Another disturbing set of findings about economic insecurity comes from the latest annual survey of Canadian family finances (families of two or more people) from the Vanier Institute of the Family. Some of the study's findings will be familiar: for instance, after-tax income of the poorest 20 percent of Canadian families (two or more people) rose by just 19 percent between 1990 and 2009; the incomes of the richest 20 percent rose by 35 percent. We know from other studies that the trend toward increasing inequality is even more extreme when we look only at the top one percent of the Canadian income distribution: 246,000 people with an average income in 2007 of $404,000 who accounted for 32 percent of all the growth in incomes between 1997 and 2007.

Source: Department of Finance Canada.
This illustration is taken from an official Government of Canada publication;
it is used here without Government of Canada endorsement.

Other Vanier findings are less familiar, and more disturbing. For instance, Canada's official unemployment rate in early 2012 would have been 9 percent, rather than 7.6 percent, if the participation rate had been as high as before the recession; 'discouraged workers' who have given up the search for work are not counted as unemployed. And although the overall insolvency rate (bankruptcies and proposals to creditors per 100,000 population) dropped slightly in 2010 and 2011, insolvencies among people aged 55-64 increased by almost 600 percent between 1990 and 2010. Among people over 65 they rose by 1747 percent. This suggests that one of the signal accomplishments of postwar Canadian social policy, cutting the percentage of poor seniors to one of the lowest in the OECD, may be in danger.

As noted in an earlier posting, addressing the possible consequences for population health of such trends unavoidably raises questions of public health ethics. One approach would be to set up an elegant prospective epidemiological study, wait 10 or 15 years, and hope that the casualties, their survivors, or someone are still interested in the answers. Another approach, adopted by the Commission on Social Determinants of Health, is to act on what we now know or can presume with a high degree of confidence, drawing on various sources of evidence and research traditions. So far, our political leaders – and, it must be said, a few of our public health colleagues – seem more interested in punishing the poor and economically insecure, or just ignoring them, than in equalizing opportunities to lead healthy lives. Inequality trends are important for many reasons, but one is that they give the lie to claims that such equalization is unaffordable.

Sir Michael Marmot, who chaired the Commission on Social Determinants of Health and later led a review of influences on health inequalities in England, has called for "a social movement, based on evidence, to reduce inequalities in health" ⁽¹⁾ and even claims to identify the beginnings of such a movement. Has such a movement begun to coalesce, and what are the prospects for its success?

In a recent book on women's resistance to workplace sexual harassment in the United States, Carrie Baker defines social movements as "a mixture of informal networks and formal organizations outside of conventional politics that make clear demands for fundamental social, political, or economic change and utilize unconventional or protest tactics" (p. 4) and argues that the resistance she studied fits that definition, even though much of the action took place in courtrooms, administrative hearings, and Congressional committees. Crucially, the coalitions that formed to fight sexual harassment connected women who were not otherwise similarly situated in socioeconomic terms. Restaurant workers, middle managers in banks and federal agencies, and lawyers trying to make partner in their firms were united - sometimes temporarily and precariously – by lack of legal protection from sexual harassment by male colleagues and superiors.

ACT UP demonstration, St. Patrick's Cathedral, New York City, December 10, 1989. Photo: Richard B. Levine

A parallel can be drawn with what is almost certainly the most successful contemporary health-related social movement, that involving treatment and prevention of HIV/AIDS. At the forefront of that movement was the AIDS Coalition to Unleash Power (ACT UP), co-founded in New York City in 1987 by playwright Larry Kramer, who was to become identified as the public face of the movement. ACT-UP quickly adopted the tactic of mounting high-profile demonstrations in places including Wall Street, the US Food and Drug Administration in Washington, DC, and St. Patrick's Cathedral (to protest against Catholic opposition to AIDS education and condom distribution). Some of ACT UP's approaches were controversial, but it "added enterprise and erudition" to confrontation, and the organization and its tactics quickly spread nationally, and even internationally.

In the early years of the epidemic, AIDS was an equal opportunity killer. This is less true today, yet the solidarity forged in the formative years of AIDS activism survives and crosses both class and national boundaries, as seen for example in the transnational support that South Africa's Treatment Action Campaign (TAC) has mobilized. That support was critical in convincing pharmaceutical companies to abandon legal efforts to prevent South Africa's government from buying lower-cost generic antiretrovirals, and TAC continues to appeal to a global audience for maintaining access to AIDS treatment.

ACT UP demonstration, Paris, 2005. Photo: Kenji-Baptiste Oikawa, reproduced under a Creative Commons Licence.

Here's the rub.

Effective social movements are not based on evidence. Social movements can use evidence in various creative ways, but they are based on rage, hopelessness, desperation, hope, or combinations of these. That's where their energy comes from. Normally, as shown by the examples of ACT UP and resistance to sexual harassment, their protagonists share a particular vulnerability even though they may otherwise have little in common. If we go farther back in history, the movement for female suffrage and the trade union movement are useful case studies; movements to abolish slavery, in which some protagonists had no personal stake yet were willing to place themselves at considerable risk, provides a partial counterexample.

What shared passions or vulnerabilities (and effective social movements require at least one of these, and often both) will provide the basis for reducing health inequity by way of action on social determinants of health in Canada? What more needs to be known about social movements in order to create an effective one around this agenda? The answers are far from clear, which may be why the agenda is making slow progress.

Launch of Poverty Free Ontario Campaign, Sudbury, September 2011. Photo: Cait Mitchell (used with permission).

Public health researchers and practitioners, whatever their level of commitment (which varies greatly), are at minimal risk from many of the conditions of life and work that are most destructive of health: inadequate incomes, precarious employment, hazardous exposures on the job, and the physiologically corrosive levels of stress that go along with all of those. Perhaps that is why the enterprise of health promotion still focuses far too much attention on health literacy, "choosing your sandwich with care," and similar constructs that ignore the quotidian challenges of too little money, too many demands in the workplace (including, for women in particular, the domestic workplace), and too few hours in the day. Prof. Marmot's 2004 book The Status Syndrome is eloquent on the topic of these challenges. Further, few efforts appear to have been made to make common cause and build working relationships with anti-poverty organizations or the trade union movement. (I would love to hear from readers about exceptions to this generalization, in Canada or elsewhere, for future postings.)

Gratifyingly, some health professionals now understand the importance of such alliances. For example, in a special section on advocacy in the March 2012 issue of Canadian Nurse, Joyce Douglas of the Canadian Nurses' Association writes: "Front-line nurses can speak from experience and work with organizations, associations and movements that advocate for wages that people can live on, affordable housing, healthy environments and social inclusion." As Ontario and many other provinces face hard choices about how to reduce their post-recession deficits, let's hope health professionals of all kinds understand the issues and the stakes.

* A conversation with Kumanan Rasanathan helped to clarify some of the ideas presented here, but all blame rests with me.

(1) The hyperlink is to a video interview with Prof. Marmot; the phrase is also the title of his response to a series of commentaries on his two reports that appeared in Social Science & Medicine.

On February 15 the Government of Ontario released a far-reaching report on reorganizing public service provision in response to the budget deficits that followed the post-2008 recession. The central theme of the report was that “just to meet the government’s goal of a balanced budget seven years hence, the government will have to cut even more deeply from its spending on a real per-capita basis, and over a much longer period than the Harris government did in the 1990s, without the option of an immediate deep cut in social assistance rates” (p. 121). Ontarians will remember that the Harris government cut those rates by 21 percent almost immediately after coming to power. Despite some increases, in 2009 they remained (depending on the type of household receiving assistance) between 17 and 38 percent lower than in 1996 after adjusting for inflation, according to the National Council of Welfare.

The Commission says much that is important and worthwhile about health care in Ontario, starting with the recognition that Ontario does not really have a health care system, but rather “a series of disjointed services working in many different silos” (p. 152), and that Ontario health care does not perform well based on international comparisons. Well grounded hypothetical descriptions of patient trajectories spotlight shortcomings in health care performance (pp. 153, 159, 164), measured against what ought to happen as a matter of routine. The report makes a compelling case for improving coordination among the silos, through measures both large and small, and making the non-system’s current approach to complex and chronic conditions (the management of which is also very costly) more effective – all of which should have been accomplished long ago, for reasons unrelated to cost. The report urges “aggressive” negotiation with the Ontario Medical Association on compensation (p. 189) – bringing to mind Robert Evans’ long-standing insistence that "cost containment is in aggregate income control, by definition" – and, perhaps more importantly from a health policy perspective, insists on moving “critical health policy decisions out of the context of negotiations with the Ontario Medical Association and into a forum that includes broad stakeholder consultation” (p. 185).

A leaner, meaner Ontario: Locked out workers at the Electro-Motive plant in London, Ontario, January 2012. Photo: CAW Media; reproduced under a creative commons licenceAlthough such changes are overdue, hard questions remain unanswered. The Commission proposes to strengthen Ontario’s 14 Local Health Integration Networks (LHINs, the province’s variation on regional health authorities) so that they can improve coordination among silos and health care management in general. But can these entities accomplish such critical tasks as ensuring that best practices are rapidly adopted province-wide? What are the pitfalls of specifying that the accountability of LHINs, currently with no requirements for public participation, is to the Ministry of Health, as per the Commission’s recommendations, rather than to the clients they serve? And the proposed transformation of an organization called Health Quality Ontario, now an advisory body, into “a regulatory body to enforce evidence-based directives to guide treatment decisions and OHIP [Ontario Health Insurance Plan] coverage” (p. 186) could be a dream or a nightmare. Since “nothing works” is a fiscally attractive conclusion, we can imagine immense pressure to compromise transparency and scientific integrity, and ignore standard of proof issues, in the interests of cost containment.

The report further acknowledges the importance of social determinants of health: “Socio-economic factors such as education and income explain 50 percent” of population health outcomes, and the physical environment another 10 percent (p. 132) although the percentages, drawn from a Canadian Senate Committee report, appear to be guesstimates and no supporting evidence is provided. This acknowledgement is ironic, to say the least, given what the Commission has to say about social policy.

The Commission’s proposed 0.5 percent limit on annual spending growth for all social programs means that no increase in social assistance rates is envisioned, despite the decline from mid-1990s levels. In fact, the Commission proposes slowing the provincial takeover of social assistance costs downloaded to municipalities during the Harris era (p. 483), prolonging the nineteenth-century practice of leaving “poor relief” to local governments. (Unfortunately, some surveys find that nineteenth-century attitudes toward economic hardship remain widespread.) No new resources are contemplated for social or affordable housing, despite the existence of multi-year waiting lists in much of the province. As the Toronto Star’s Thomas Walkom and a policy analyst for the Ontario Nurses’ Association have pointed out, despite Drummond’s long career as a professional economist, the report ignores the employment consequences of taking billions of dollars out of the provincial economy. Walkom predicts that implementation of the Drummond recommendations would cause unemployment in Ontario to rise to 11 percent by 2018, “even without another global crisis”. Poverty reduction is nowhere acknowledged as a legitimate goal or priority of government; indeed, the word “poverty” appears only six times in the text of the 562-page report.

To put this discussion into context: on Thanksgiving weekend in 2010, the Premier of Ontario was quoted by CBC News as urging Ontarians to donate to food banks, and in March, 2011 395,000 Ontarians relied on a food bank to feed themselves at least once. Rents and food prices are not going down. So the Commission has said to a significant proportion of Ontarians: forget about any hope that your opportunities to lead a healthy life will improve before 2017-2018. The cupboard is bare.

But is it, really? In order to answer this question, we have to look at both the revenue side and the expenditure side of Ontario’s public finances, in historical perspective. The Commission itself emphasizes that “spending is neither out of control nor wildly excessive. Ontario runs one of the lowest-cost provincial governments in Canada relative to its GDP and has done so for decades” (p. 5). Further, it notes that the provincial treasury’s “own-source revenues” – taxes and user fees collected by the province, as distinct from revenues received from federal transfers – as a percentage of provincial Gross Domestic Product (GDP) were considerably lower (13.65 percent) in 2010-2011 than in 1999-2000, midway through the Harris era (15.9 percent). Although precise comparisons are impossible, this is consistent with estimates by the Canadian Centre for Policy Alternatives that, every year since the start of the century, provincial tax cuts (mainly in personal income tax rates) begun in 1995 have reduced revenues by between $10 billion and almost $18 billion relative to the revenues that would have been received if tax rates had remained at their 1994-95 levels. In other words, well before the post-2008 and its undeniable effects on revenue stream, the province’s fiscal capacity was suffering from major self-inflicted wounds.

The Commission was instructed not to consider the possibility of raising taxes. However, as shown in the illustration, if we accept the Commission’s estimates of the growth of the provincial economy and the spending restraints incorporated into the Drummond Commission’s “preferred scenario,” but are willing to consider tax increases sufficient to return own-source revenues as a percentage of provincial GDP to their 1999-2000 level by 2017-2018, we see that the budget is in surplus by more than $22 billion. Stated another way, if the province were to pursue what Hugh Mackenzie of the Canadian Centre for Policy Alternatives has called “an adult conversation about the public services we need and the revenue we are going to have to raise to pay for them,” the provincial budget could be balanced in the target year while making available $22 billion more than the Drummond projections for program spending. According to one commentator the province is not even planning pre-budget legislative hearings, thus making it difficult to start such a conversation. Indeed, the Commission’s description of the provincial budget as “a powerful educational tool” (p. 13) suggests that most of the key immediate decisions have already been made. Its proposal for a centralized expenditure management process involving the Premier’s Office, Cabinet Office and Ministry of Finance that “should stay in place for at least several years” warns of little room for debate in the future (pp. 140-141). Shouldn’t public finance be a matter for public debate?

At several points in its report the Commission underscores the difficulties created by the government’s refusal to consider tax increases, anticipating (for instance) a $38.5 billion shortfall in financing planned and necessary public transit investments in the Greater Toronto and Hamilton Area. For those who can afford to drive everywhere, this means only the inconvenience of more traffic jams; for those who can’t, it may seriously limit mobility … and of course that foregone investment also means lost employment. The Commission states that its budget-balancing strategy would mean “tough decisions that will entail reduced benefits for some” (p. 69) – although not, it seems, for everyone. On the matter of soaring compensation for people like Drummond’s fellow commissioners at the top of public sector salary scales, the report says that “focus must remain on the larger picture, which is the government’s need to get the right people into the right positions at a cost that is both compatible with its fiscal circumstances and appropriately aligned with private-sector compensation” (p. 138). Well, workers at Electro-Motive Diesel’s London, Ontario plant know about that kind of alignment: they were locked out after refusing a 50 percent pay cut before the parent company closed the plant and moved the work to Indiana. In the Ontario of tomorrow, it seems that what Saskia Sassen calls “the savage sorting of winners and losers” characteristic of the contemporary global marketplace is to be accepted, and indeed welcomed.

Any assessment of the Commission’s implications for population health (and never was there a better example of the need to apply health equity impact assessment to macro-scale economic and social policies) should keep this in mind. As pointed out by (among others) economist Erin Weir of the United Steelworkers, there is quite a bit in the report that those of us committed to social justice can support. At the same time, the report is about much more than public finance. Effectively, it recommends for Ontario a variant of the structural adjustment programs* of marketization and social policy retrenchment demanded by the International Monetary Fund in return for loans enabling low- and middle-income countries to reschedule their debts to external lenders, in the process creating widespread economic hardship and seldom leading to long-term economic improvements. Equity, for both the IMF and the Drummond Commission, was an unaffordable luxury. Against a background of worsening economic disparities that would be further magnified in the future envisioned by the Commission, what is the future of health equity in Ontario? And who will decide?

* For readers unfamiliar with the history of structural adjustment, two excellent recent review are Babb, S. (2005), The Social Consequences of Structural Adjustment: Recent Evidence and Current Debates, Annual Review of Sociology, 31, 199-222 and Pfeiffer, J. & Chapman, R. (2010), Anthropological Perspectives on Structural Adjustment and Public Health, Annual Review of Anthropology, 39, 149-165. Unfortunately, so far as I know neither of these is available on an open-access basis.

Many readers will remember the sequence of events in which former football star O.J. Simpson was acquitted of the murder of his estranged wife and a friend in a criminal trial, yet found liable for damages in a civil suit brought by the family of one of the victims. Leaving aside the sociological roots of the not-guilty verdict in the United States' tragic history of racial antagonisms, in analytical terms the discrepancy can be explained with reference to the higher standard of proof in a criminal trial (proof beyond a reasonable doubt) than in a civil proceeding where a claim for damages can be sustained on a preponderance of the evidence or, in some common law jurisdictions, on the balance of probabilities.

The idea of a standard of proof is critical to understanding the question posed in the title of this posting. A classic article published in 1978 by economist Talbot Page (1) used this concept to analyze public policies toward "environmental risks" like toxic chemicals, which share such characteristics as incomplete knowledge of the mechanism of action, long latency periods between exposure and illness, and irreversibility. He pointed out that most forms of scientific inquiry are organized around minimizing Type I errors – that is, 'false positives' or incorrect rejections of the null hypothesis. Page used the analogy of the standard of proof in criminal trials, and went on to argue that minimizing Type I errors may be a thoroughly inappropriate principle when applied to use of scientific evidence in public policy, because it fails to take into account uncertainty and consequences. Stated another way, "a risk/benefit assessment," albeit often an implicit one, "is part of every public policy action which is based upon the interpretation of the results of a scientific investigation." (2)

Waiting for "evidence of dead bodies" may be inappropriate when responding to health threats from environmental hazards.
Photo by biofriendly, reproduced under a Creative Commons licence.

This point has often been lost sight of in controversies about controlling toxic exposures in the environment and the workplace, with industry resisting regulation by demanding stronger – usually epidemiological – evidence and trying to cast the issue as one of scientific uncertainty: demanding what another economist has described as a "tobacco industry standard of proof." (3) Page correctly pointed out that: "In its extreme, the approach of limiting false positives requires positive evidence of 'dead bodies' before acting." This is, in fact, the standard of proof that has often been applied to research on the health effects of environmental hazards. A further point of importance is that the conventional threshold of statistical significance – 95 percent – may require extremely large and unmanageable sample sizes when the prevalence of a particular adverse outcome is only moderately elevated over background levels. (4) As Page pointed out, "there is literally no information content in a negative finding unless there is an analysis of ... the probability of a false negative." (1)

Choosing a standard of proof for purposes of public health policy therefore is unavoidably an ethical decision, having to do – as yet another author pointed out at around the same time – with the relative acceptability of being wrong in different kinds of ways (5) while we wait for evidence that may or may not be obtainable. Interestingly, a workshop on conceptual and methodological issues in public health science held at the University of Cambridge in 2010 revisited these questions, suggesting that understanding of them in the relevant research communities remains incomplete, even as they remain topical with respect to such issues as environmental causes of breast cancer .

The question of how much evidence is needed for action on social determinants of health underscores the value-laden nature of choices about the appropriate standard of proof. At least two issues are critical.

First, what kinds of research findings are relevant? Clinical epidemiology now widely accepts a hierarchy of evidence with the randomized controlled trial (RCT) at the top; presumably, this is what two authors writing on global health governance had in mind when they claimed that "[f]ew global health interventions are evidence-based, and interventions to improve population health among the poor are often untested ..." To some of us, this assertion is nothing short of bizarre, and neglects the fact that many interventions outside clinical settings cannot be assessed using RCTs, for reasons of ethics, logistics, or both. Colleagues and I pointed out a decade ago, in the context of research on preventing mental illness, that "choosing certain research strategies and standards of proof means the big questions ... probably will not be studied in ways that demonstrate the effectiveness of larger-scale, contextual interventions, and even the small questions will be asked in ways that seriously circumscribe the set of possible answers."

A methodologically pluralist approach, organized around what a former colleague calls a "portfolio of evidence," will yield more meaningful and policy-relevant answers. Unbeknownst to us, Michael Marmot had made a similar point the previous year in a general discussion of evidence for influences on population health: "The further upstream we go in our search for causes ... the less applicable is the randomized controlled trial. .... We must therefore rely on observational evidence and judgment in formulating policies to reduce inequalities in health. In this process, the best should not be the enemy of the good. While we should not formulate policies in the absence of evidence to support them, we must not be paralyzed into inaction while we wait for the evidence to be absolutely unimpeachable." (6) He continues to make this point.

395,000 Ontarians received help from food banks in March, 2011.
Image courtesy Ontario Association of Food Banks.

Second, is it necessary to wait for evidence that a particular policy or intervention leads to improved health outcomes, or is it sufficient to have evidence of reduction in risk factors or what might be called intermediate biological variables (like markers of allostatic load, in the context of prolonged stress) that are known to have an adverse effect on health outcomes? This question gains urgency from knowledge of the cumulative effects of negative contextual influences on health over the life course: "waiting for dead bodies" in this case, as in others, can amount to carrying out a large-scale experiment on non-consenting subjects, the results of which may not be available for a generation. Obviously, ongoing evaluation of interventions and policy changes is important, but how much more do we need to know before (for instance) doing what it takes to reduce food insecurity among people for whom eating a healthy diet while paying market rents is arithmetically impossible?

This is a rather polemical way of stating the question, but it is useful in order to get at the hard politics of debates about evidence. Many policies and interventions needed to reduce health disparities by way of social determinants of health will be explicitly redistributive – starting with reductions in income inequality, as noted in a forthcoming editorial in the American Journal of Public Health. As mentioned, companies facing costly regulation of their activities have long found it attractive to frame their opposition as based on the insufficiency of scientific evidence. Similarly, those who stand to lose from tackling "the inequitable distribution of power, money, and resources" – one of the three overarching recommendations of the Commission on Social Determinants of Health – may frame their opposition in terms of the need for more evidence rather than simple self-interest. One-percenters, and those on a fast track to that status, are not a natural constituency for redistributive policies. This is not of course the only explanation for hostility to the social determinants of health agenda, but it cannot be disregarded. Against this background, it's especially important to keep in mind that the appropriate questions are not only about the strength of evidence, but also about how uncertainty should be resolved in a context where "deferring a decision is a decision in itself." They are, in other words, rooted firmly in the domain of public health ethics. Only by insisting on this point can we be sure that debates about when and how to act involve – as they should – the language of values and social justice.

(1) Page, T. (1978) A Generic View of Toxic Chemicals and Similar Risks. Ecology Law Quarterly, 7, 207-244.

(2) Darby, W. (1979) An Example of Decision-Making on Environmental Carcinogens: The Delaney Clause. Journal of Environmental Systems , 9, 109-117.

(3) Crocker, T.D. (1984) Scientific Truths and Policy Truths in Acid Deposition Research. In T. Crocker, ed., Economic Perspectives on Acid Deposition Control (pp. 65-79). Ann Arbor Science Acid Precipitation Series vol. 8. Boston: Butterworth.

(4) See e.g. Higginson, J., Muir, C.S., Muñoz, N. (1992) Human Cancer: Epidemiology and Environmental Causes (pp. 39-44). Cambridge: Cambridge University Press.

(5) Jellinek, S. D. (1981) On the Inevitability of Being Wrong. Annals of the New York Academy of Sciences, 363, 43-47.

(6) Marmot, M. (2000). Inequalities in Health: causes and policy implications. In A. Tarlov & R. St.Peter, eds., The Society and Population Health Reader, vol. 2: A State and Community Perspective (pp. 293-309). New York: New Press.