Viewpoint: ‘Do no significant harm’ principle in Horizon Europe is a chance to rethink policy

The European Commission’s acknowledgement that research and innovation have the potential to generate environmental harms can be viewed as a landmark in the history of research policy.

However, making researchers promise to ‘do no significant harm’ is not the right way to address this issue. Rather, research and innovation policy should be reconfigured to allow researchers to ‘stay with’ the harms they (might) do.

At the end of 2019, the European Commission heralded its European Green Deal as a bold, much needed policy to systematically promote the development of a more sustainable economy across the EU.

The initiative was accompanied by an investment plan seeking to mobilise some €1 trillion, in part within a framework regulation that is designed to facilitate sustainable investment. This informally named, ‘taxonomy regulation’ states that economic activities must make significant contributions and to ‘do no significant harm’ to EU environmental objectives. On the back of this, at least 35% of the Horizon Europe budget, around €35 billion, is now expected to be disbursed with this principle in mind.  

The application of the EU Taxonomy regulation’s do no significant harm principle in Horizon Europe did not go down well with MEPs, who claimed it added to the bureaucratic overhead of an already paperwork-heavy application process.

To date, guidance on the application of do no harm in Horizon Europe proposals is limited and much remains unspecified. That is playing into complaints that evaluators and researchers will not understand what to do in practical terms.

But given that these same MEPs purport to be in favour of protecting nature, threatening legal action against the Commission for advancing do no harm as a principle in Horizon Europe seems misguided. This is especially so since Europeans increasingly consider the climate crisis a top priority, placing it above the current economic crisis in their list of priorities.

In a paper published in the environment and society journal Ambio, we offer practical reflections on an alternative way to implement and realise the important ambitions of the do no significant harm principle. We argue more attention should be paid to addressing the root concern of how we can begin to understand and do something about all the harms we create through research and innovation, even when well-intentioned. In an age of increasingly destructive human impacts on the environment, and with these environmental impacts feeding back to humans, sticking our heads in the sand is no longer an option.

What constitutes harm

Looking at current approaches to embedding the do no significant harm principle in other economic activities, MEPs can be seen to have grounds for their concerns. The Taxonomy Regulation technical expert groups charged with specifying what constitutes harm have produced 593 pages of guidance that define a universe of possible harms across macroeconomic sectors.

It reads like the foundations for a technocratic and bureaucratic system that makes the application process for Horizon Europe look like a walk in the park.

There is also the issue of what effect the guidelines will have. A case in point is the political back-and-forth over whether nuclear energy qualifies as environmentally sustainable for the purposes of the do no significant harm principle.

We don’t take a side on this debate one way or the other, except to point out that it illustrates how determinations of harm cannot be technocratically, unilaterally handed down. Instead, questions of significant harm need to be negotiated among humans, non-humans, and ecosystems experiencing harm, since harms and their significance are determined by the contexts in which they arise.

What’s the harm in that?

Drawing on feminist studies of science and technology, especially the work of Donna Haraway, professor emerita at the University of California, we argue that questions of significant harm need to be viewed in specific contexts. This concept of ‘situatedness’ calls for scientific knowledge to be seen as enmeshed with the cultural and social context in which it is generated.

Adopting a perspective in which situatedness, and the perspectives of humans and non-humans, and their ecosystems in relationship, is the central consideration, requires that research and innovation is managed from an understanding that there is no universal, objective viewpoint from which one might determine which research is beneficial or harmful, for whom, and to what degree.

Consequently, an era where doing no significant harm is a central aspiration – and that goes hand in hand with generating significant contributions to environmental objectives - requires a new set of research and innovation governance principles and practices.

First, understanding of harm needs to be expanded to factor in time, space, and marginalised actors. A situated approach to do no harm benefits from a broader view of the paradoxical generosity and miserliness of time. Some harms emerge immediately – a life extinguished for example – while others slowly accumulate over years.

Geographically, harms may emerge close to a research facility, but could also be displaced, for instance through supply chains or energy and data centres, to locations continents away.

Finally, in terms of marginalised actors – whether future children unable to speak for their generation, traditionally excluded stakeholders, charismatic megafauna, old growth forests, or trophic keystone species – need appreciation and legitimate attention when interrogating and seeking to deal with the harms of research and innovation.

Second, people involved in science, from researchers and funding agencies, to industry need to be supported to embrace ambiguity. The approach of the European Commission now rests on the assumption one can say, in clear terms, whether something is harmful. Yet occasions when this is the case may be an exception rather than a rule. In addition to emerging in unexpected, non-linear ways, harms co-exist with benefits that generated in tandem.

The majority of harms discovered through a diversified understanding will be ambiguous—and that is okay. Rather than ignoring such ambiguity in service of compliance, and perpetuating harms in the process, a situated approach would recognise and encourage the discovery and creation of spaces where ambiguous harms can be appropriately engaged.

Finally, once and as such spaces are created, an ethos of ‘staying with’ the harm needs to be adopted. A situated approach to engaging with do no harm takes as a given that relationally, a degree of harm is inevitable in human activities, and research and innovation are no exception.

Rather than operating under the delusion that we can avoid harmful research altogether, or that by checking a box at the start of a proposal one can avoid future harm, we urge European researchers to develop innovative mechanisms for revealing, understanding, and inclusively tending to harms as they emerge and evolve over time. Staying with harm in this manner would mean developing patient, methodical approaches and instruments that create space and time for cross discipline, cross sector, and more-than-human relations (species and ecosystems) to work together and navigate ways to tend and redress harms.

We live in an age when harm created by pursuing a western, industrialised mode of existence is unsustainable. We genuinely applaud the European Commission for seeking to embody the do no significant harm principle in economic activities, including research and innovation

However, if MEPs are concerned with bureaucratic weight of the important ambition of doing no significant harm in research, the question should not be how to get the principle dropped, but rather how to support the Commission to better implement it in the context of research systems.

From this standpoint, as we have elaborated, significant harm from research ought not be about how to make these harms go away, but rather how to more honestly account for them in our research programmes, processes, projects, and legacies.

Dr. Michael J. Bernstein is a scientist at the Center for Innovation Systems and Policy at the Austrian Institute of Technology, GmbH.

Dr. Robert D. J. Smith is a senior research fellow at Science, Technology & Innovation Studies, School of Social & Political Science, The University of Edinburgh.

Dr. Thomas Franssen is a senior researcher at the Centre for Science and Technology Studies of Leiden University.

Dr. Mandy de Wilde is a postdoctoral researcher at the University of Amsterdam, Faculty of Social and Behavioural Sciences, Programme group: Anthropology of Health, Care and the Body.