Sunday, March 9, 2014

1994 Contract with America: Lessons for Risk Assessment

This happened 20 years ago but I think this episode still provides food for thought today.   Back then I subscribed to a Business Publishers, Inc., Newsletter that was entitled "INDOOR POLLUTION NEWS".   I Googled it recently and seems to be gone; however, in one of their issues from around 1994 they  presented an editorial opinion on Risk Assessment (RA) that I think is still worth discussing in 2014 .  The piece is presented below:

"RISK ASSESSMENT - One Section of the Republicans Contract with
 America calls for regulatory agencies to use risk assessment, that
 is the scientific measurement of risks to be regulated-before rules
 are promulgated.  The focus on risk assessment by business and then
 made into a campaign issue by the Republicans seems clearly a
 subterfuge to gut environmental laws. ...  The science behind much of
 risk assessment is costly and in some cases problematic, rather than
 err on the side of caution for public and environmental health, the
 thrust now will be to negate rules and regulations that cannot be
 backed by ironclad science."

Wow!  This really struck me at the time because it was the strongest and most direct statement I have seen relative to the fears of the governmental, regulatory risk assessment/management community.   It got me to thinking about what I believe regarding this subject.   What I came up with long ago I still believe but with perhaps some of the more youthful naivete removed.  

My opinion is that RA is just a tool but it should be a tool that is used honestly.  If one uses the worst case then one should also present the "best" case and, if possible, the "average" case in a RA.  UNCERTAINTY born of a lack of basic knowledge makes worst cases worse while it broadens the error bands around the evaluation of risk in general.  Ideally and perhaps, in retrospect, naively in 1994, I saw the proposed legislation as asking for the honest reporting of risk knowledge and uncertainty.   Indeed, open reporting does not have to result in the “gutting” of environmental laws but it could allow for better decisions and better allocation of resources.  One-sided RA (only worst case) tends to hide behind the appearance of certainty.  Serious decisions need to have all the "cards on the table face-up" and all the uncertainty revealed in the most open and honest manner we are capable of. 

This blog has been discussing OELs of late.  There is plenty of uncertainty around the setting of OELs but the gist of the message so far has been that we need to do the best we can in rationally describing the process and for me that mean quantitative modeling predicting the range of risk at the OEL.   If the various models are very uncertain they are at least open relative to their particular quantitative assumptions.  It is this openness that can lead to identification of areas for improvement (spelled "research" and "money"); however, if we continue to cling to a somewhat hidden or ill-defined basis for setting OELs, then I am afraid that improvement and progress will come very slowly if at all.

Finally, it should be understood that the technical details and error bands around any RA only represent some of the “cards", we still have plenty of subjective political and cultural values that need to be acknowledge, openly faced, reported and factored into most decisions including OELs.  My vote is  that we take the onus off of technical RA to do everything and recognize it as a valuable tool that needs some nurturing (again that is spelled “research money”) if it is to really make good on its potential to render more light than heat regarding any question of risk.

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