thought, would override the vagaries of national politics and culture in specific issue areas, whether nuclear power, pollution control, pharmaceutical regulation, the management of chemical pesticides, or the environmental release of genetically modified organisms (GMOs).
One of the more interesting findings of comparative policy research in recent years has been the failure of these expectations. Although policy agendas, broadly speaking, have converged on a host of issues worldwide, specific national policies for managing health, safety, and environmental risks continue to diverge, even when they are ostensibly based on the same bodies of scientific information. Intriguingly, evidence deemed persuasive in one national policy context does not necessarily carry the same weight in others. Even when policy outcomes converge, as for example in the informal moratorium on nuclear power across most of Europe and the United States, the underlying technical justifications are not invariably the same.
The literature on comparative policy provides some notable examples of cross-national divergences in the regulation of technological hazards. Thus, a four-country comparison of U.S. and European chemical regulation in the mid-1980s showed that European nations neither gave the same priority to carcinogens as did the United States nor developed comparable programs of testing and risk assessment (Brickman et al., 1985). Parallel differences have been observed even between the arguably more closely coupled policy systems of Canada and the United States (Harrison and Hoberg, 1994). National strategies for regulating air pollution have similarly diverged in priority setting, timing and severity of controls, and the choice of regulatory instruments. European countries, for example, were markedly slower to regulate airborne lead and chlorofluorocarbons than the United States. More recently, Europe has overtaken the United States in cutting sulfur emissions regarded as a precursor of acid precipitation. Biotechnological products created through genetic modification have encountered substantially different entry barriers on the two sides of the Atlantic, with significant cross-national disparities observable in the environmental release of GMOs (Jasanoff, 1995), the public acceptance of genetically modified foods, and patent protection for genetically engineered animals.
Numerous explanations have been offered for these persistent policy divergences, which reflect in turn underlying differences in societal perceptions and tolerance of risk. The simplest causal factor advanced by social scientists is economic interest—most plausibly invoked when the burdens and benefits of regulation fall disparately in different national contexts. For example, the relatively muted character of antinuclear protest in France (Nelkin and Pollak, 1981), as well as that nation's exceptionally low-key response to the Chernobyl disaster, have been attributed to the heavy French reliance on nuclear power as an energy source. Similarly, generators of acid precipitation such as the United States and the United Kingdom have been notably less aggressive in seeking control policies for sulfur oxides than the recipients of pollution, such as Canada and Norway.
Historical explanations seem to carry weight in other cases: Germany's unusual hostility to biotechnology in the 1980s no doubt reflected a distaste for