RISK ASSESSMENT: THE TWO-EDGED SWORD
PAUL M. SCHLOSSER
(Updated, 3-22-97.)

"There is no perfect process" -Morris Hudgins, Minister, UUFR

Contents

Issues
Purpose
Disclaimers

[Comment Form]

Conceptual Models in Environmental Policy

An Objective Environmental Dictionary

On the Value of Human Life

What good is this theory?

On a Rational Approach

Issues:

  1. The majority of Superfund toxic waste sites in the US are in or near low-income communities. Likewise, communities located closest to chemical plants are predominantly low- income.


  2. Some people living in these areas have suffered adverse health effects which are almost certainly due to the resultant exposure to synthetic or processed chemicals. (I say "almost certainly" because causality cannot be proven in a strict, scientific sense.)


  3. While most of these cases resulted from emissions or dumping that occurred prior to existing environmental legislation and industry product stewardship, there are some documented cases where recent or current exposures have been linked to adverse health effects here in the US.


  4. The fact that excess risks have been imposed on poor communities in the past, and that those risks have not been completely eliminated by current environmental legislation and industry initiatives, has lead to a widespread perception by people in these communities that they are being placed at excess risk–paying the "price" of chemical technology#150;so that others in society can benefits. (I use the term "perception" here in a neutral sense; this may or may not be the fact, but it is believed to be so.)


  5. Grassroots and environmental organizations, in what is now called the Environmental Justice (EJ) movement, have therefore taken the position that allowing higher levels of chemical exposure in poor communities than exist in wealthier communities is unjust, and that the only safe exposure is no exposure


  6. There is not enough wealth in the entire US economy to clean up all Superfund sites in a short length of time. Likewise, while goals such as "zero emissions" or "zero risk" may be admirable, they are neither technically feasible nor could they be enforced if enacted into law. Therefore, priorities must be set in site remediation or clean-up, and legally "acceptable" levels of emissions and/or risk must be determined. This is unavoidable. Finally, setting extreme goals in search of zero risk of one type can result in much greater risks to human health of another kind. One tragic example occurred when, in attempting to eliminate the very small (perhaps negligible) risk of cancer associated with water chlorination, a very large number of deaths were caused by the resultant cholera epidemic. Perhaps the worst aspect of t his tragedy was that scientists at CIIT had been generating and publishing a large body of scientific data which indicated that the risk from chloroform, the byproduct of water chlorination which gives rise to cancer concerns, is much lower than was originally estimated EPA. This is because the original experiments administered the chloroform to rats in a single bolus dose in corn oil, which is completely irrelevant to human consumption patterns, and the risk does depend strongly on the pattern of intake.


  7. The current trend in risk management practices, in part spurred by congressional mandate in the US, is to use the tools of risk assessment to set site-specific clean-up levels, priorities, and legal exposure limits.


  8. Initial risk assessments for many chemicals employed large, "conservative," safety factors. For example, an initial assessment might determine the "safe" level of PCBs in soil, presuming that a family with children lives at the site for many years. (Love Canal, is an example of a an old industrial site converted to residential use.)


  9. The presumption is that by restricting the future use of a site (for example, limiting it to industrial use, making exposure to children unlikely), and then using recent scientific toxicity data to update the risk assessment accordingly, less stringent levels of clean up will be indicated for some sites. Indeed, if this were not the case, then the new risk assessments would not help in priority setting, which is the goal. Similarly, the large, conservative, safety factors in existing risk assessments used to set regulatory emissions levels may, in some cases, place costs on industry well beyond the point where any health benefit may be realized, and it is believed that updated risk assessments may ease this burden.


  10. The EJ movement presumes that this use of risk assessment is simply a means of continuing if not worsening the existing injustices. They claim that risk assessment is so unreliable that it is not even "science" and have taken the position that its use in risk management decisions is completely unacceptable. To get a full "appreciation" for the EJ perspective, see the Grassroots Glossary.


  11. Current regulatory levels are based on risk assessments.


  12. Cases of adverse health effects due to chemical exposure have been proven in court, providing relief or compensation to poor communities, using risk assessments.
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Comment Form

Purpose:

I created this page as an attempt to present the issues, views, and facts in a balanced manner as a tool for reaching resolution.

There may be differences in "language," such as what people mean when the use terms like "risk assessment," that are resulting in miscommunication; one purpose is to create a list of value- neutral definitions. Any real solutions will require dialogue and compromise, for which these are needed.

I think that the current position of the Environmental Justice (EJ) movement on risk assessment does little, if anything, to advance their cause. In fact, I believe that this stance drives a wedge between themselves and individuals who are otherwise sympathetic to the cause of social justice. While the opinions and concerns of all citizens, particularly people from potentially impacted communities, should be heard and considered, I fear that this stance will be seen as so untenable by risk managers that the managers will discount any other message coming from EJ.

An example of how environmental concerns are being "slammed" is found in Steven Milroy's Science Without Sense: The Risky Business of Public Health Research, and throughout his Junk Science Home Page. Personally, I find that Mr. Milroy is on the mark in some cases, but that he also knocks some very legitimate concerns. (I will deliberately refrain from saying which is which here.)

Thus, there is a perception by those in the chemical industry that the amount of risk imposed on poor communities is being exaggerated by the EJ movement. Basically I see this is a case of the boy who cried wolf. So a third goal is to develop a list of documented cases with which the magnitude of the problem can actually be determined. Without such documentation, all we have is a mutual slamming match over who is exaggerating or not.

I have been told of actions by some chemical companies that, if true, are legitimate cause for great anger and public distrust, whether or not the total risks have been exaggerated. Such alleged actions would allow a company to avoid short-term expenses, but in the long run they may be harmful to all. The chemical industry is not monolithic, however, so this may be a case of the right hand not knowing what the left hand is doing. One company that exhibits a high level of stewardship and (I believe) truly seeks to be environmentally responsible is Rohm and Haas; an example of their practices is the implementation of a pollution Management Systems Verification procedure, in which an audit is performed with public participants involved, and the results are taken back to company management as input for future decisions on how to improve performance. Rohm and Haas has even posted the results of their audit on the web, providing ready public access, here. Therefore I seek to document both good and bad "cases," and let the evidence, or lack of it, speak for itself. Even in the absence of evidence, I hope that stating the accusations will help industry representatives who may not be currently aware of them (such as those employed by truly responsible companies) understand the anger which drives the EJ movement.

I also seek to document cases where the tools of risk assessment have been used to the benefit of poor communities, showing that it is indeed a two-edged sword.

My current position is that it would be foolish to make decisions on risk management without risk assessments, and I will seek to explain why.

Finally, I seek solutions to the current impasse between EJ and risk management practices. I will propose some, but I also hope for constructive suggestions by many "stake-holders." It's one thing to decry a practice, position, or policy, but this does no good unless workable alternatives are found. The economic and political realities of the world we live in constrain our choices. They are unavoidable.

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Disclaimers:

  1. This document is a description of my views on and understanding of a very sensitive issue. This does not necessarily represent the views of my employer. It has not been submitted for internal review, and certainly has not been approved for publication. It is published via my personal, home net account, and the work is being done on my own time. On the other hand, this does not mean that such a document would be automatically "suppressed." Given a good list of references, I would expect to be able to submit a paper based on this page to a peer-reviewed journal (leaving out opinions on ethics and items such as the quote given at the top). In fact, I hope that this effort will indeed lead to a formal publication. It is an effort to determine and report the truth, whatever that is.


  2. The document is based on a very frank and informative discussion with a person in the Environmental Justice (EJ) movement. (I have currently decided not to name my EJ colleague since others in that community consider anyone who works with industry of government as having been "co-opted.") The tenor of that discussion along with the individual's professional involvement, have resulted in a fair level of mutual trust. On my part, I have accepted a number of this person's statements as factual and so presented them here, either with some "interpretation" on my part or as allegations. Tentative plans have been made to begin creating a list of references or documentation of actual injustice. If you have a reference or cases you would like to submit, send it me by e-mail and I will include in the "collection." Likewise, you can challenge any of my statements, preferably with verifiable facts.


  3. This is a "living document," which is another way of saying that it will be "under construction" for quite some time. In hopes of initiating a civilized debate ASAP, I'm publishing it as is. Also, I am willing to include other opinions submitted by you, the reader if I find them convincing. I attempt to keep an open mind and if you debate me in a reasonable manner I will respond in kind. (If you simply "flame" me, I'll just delete it!) But I will require a certain level of "proof" for any claims before I include them. Association does not prove causation–just because an illness was preceded by an exposure does not mean that the exposure caused the illness. I require a weight of evidence. You can convince me, but just saying that you "know" something will not do the job.
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