Sunday, July 26, 2015

WHY do Risk Assessment?

Chris Keil is a technically savvy colleague who has done a lot to advance the science of human exposure modeling.  He is a prime mover and editor of both editions of our bible for occupational exposure modeling:  Mathematical Models for Estimating Occupational Exposure to Chemicals.

Chris recently sent me and other colleagues a note asking for our help in a project his is doing.  An excerpt from his email is presented below:

“I’m doing a project in which I am writing on the WHY of occupational safety and health. Searching for “Ethics and OSH” yields lots of info on the Ethics of OSH *practice* but not so much the philosophical/ethical basis for it.

Lots of the written rationale for OHS is tied to it being a good idea economically. And there are vague references that it is the “right thing to do”. What I’m looking for are scholarly treatments of why OSH is the “right thing to do”.

If you know of any such treatments, please send them my way.”

In my opinion, this issue is fairly apparent and straightforward.   Indeed, I believe that our forefathers in the United States were absolutely brilliant in the fact that they wanted to separate religion from the state but also wanted to define and assert human values that were universally applicable to all people irrespective of religion.   This is not to say that religious principles, particularly Judaeo - Christian beliefs, did not drive these values.  Rather, I believe, they intended that any particular religious dogma would not be associated with the assertion and establishment of these as secular rules to live by.

The second sentence of the July 4, 1776, U.S. Declaration of Independence is particularly blunt, elegant and powerful in this regard:

“We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.”,_Liberty_and_the_pursuit_of_Happiness

I would argue that an untoward health effect from a chemical exposure or other workplace hazard is a direct threat to a person’s pursuit of Happiness if not their Life.

Indeed, some believe that the kernel for some of these ideas were voiced by the English philosopher John Locke almost 90 years earlier in 1689 when he wrote about the importance of "life, liberty, health, and indolency of body…" (ref:  same wiki web site as above).

The outdated term “indolency” is defined as:


indolency (plural indolencies)
1.     (obsolete) The lack of pain; absence of pain

It would be hard to argue that this, our country is not based on these principles.  They define who we are and how we should act as a nation and as a people.   To be true to these very clearly stated and agreed to values, it is not hard to imagine that we need to control the threats to “indolency” that might exist within our society from chemical exposure or other workplace hazards.

I have always found it to be particularly difficult and often quite inefficient to manage a risk to health from chemical exposure that was not first reasonably assessed.   Indeed, if we do not even attempt to assess a risk of chemical exposure then it is often tacitly (and often incorrectly) assumed to be negligible.  In short, doing good, proactive OSH allows us to "walk the walk" relative to the most basic of our values.

Doing good OSH may be good for the bottom line but that reason is not even close to why it should be done.   Doing good OSH lies at what should be heart of our agreed to and stated governing values as citizens and people.

As usual, I (and Chris) would love to hear your thoughts on this issue.


  1. Well said, Michael (and Chris)! It's easy to justify most OHS regulation without invoking subjective values: when the total benefits of risk reduction outweigh the resource costs society must incur to provide those benefits, we have by definition intervened in the market so as to increase total social welfare. ALL of OSHA's regulations, in my opinion as a pioneer in cost-benefit analysis, amply pass such a test: dissenters merely complain that THEY prefer not to pay costs of $X so that society as a whole can benefit by far more than $X. In kindergarten, adults would view such behavior and say these children need to be taught civility.

    But of course there are subjective values that could also be invoked. When I worked for John Henshaw at OSHA, he ordered thousands of baseball caps for the staff to wear with the motto "OSHA adds value to your business, work, and life." I always found this deflating (as I found most about working there during those years...) -- "added value" being business-speak for something like the imitation-woodgrain knob on the shift level of a car-- something that could be produced for pennies and used to add dollars to the sticker price.

    I suggested we instead emboss the caps with a line from JFK's inaugural address: "here on Earth, God's work must truly be our own." As you might imagine, this was seen as (more) evidence that I "didn't get it." As you might imagine, I felt the same about many of my (former) colleagues.

  2. I’m not certain about a connection with John Locke but from my perspective your answer likely resides in public health investigations in the wake of the industrial revolution. Independently yet somewhat simultaneously, investigations of adulterated food and drugs by Harvey Wiley and the Poison Squad, silicosis and lead by Alice Hamilton and others, and the founding of the Johns Hopkins School of Hygiene and Public Health by William Welch formed the basis for industrial medicine and hygiene based on the western European model of laboratory analyses. I suggest you focus your investigation here to identify the underlying principles manifested in quantitative measurement of current industrial hygiene and collaterally, non-occupational environmental monitoring.