ECOLOGIA NEWSLETTER Archive
Risk assessment is often presented as a rational and more comprehensive alternative to establishing rigid norms and emission standards. From the perspective of risk assessment, siting an incinerator in a remote rural area with clean air may be viewed as less of a risk than siting the same facility in a densely populated area or in a region where the ecosystem is already weakened by high levels of pollution. Using the logic of risk assessment, fewer emission controls may be imposed upon a facility sited for an area where little pollution presently exists. This may make sense from an economic point of view, if scarce resources will then be made available for pollution reduction in more heavily impacted areas.
Unfortunately however, this logic has the unanticipated consequence of encouraging the siting of very polluting or dangerous facilities in highly pristine environments where little previous damage has occurred and where the local ecosystems and population are assumed to be capable of absorbing risks comparable to those found in more industrial zones.
Residents of rural Northeastern Pennsylvania, the site of ECOLOGIA headquarters in the United States, have struggled with this dilemma for decades. A strong grassroots environmental movement has kept potentially polluting industry from coming into the area. Consequently, the water and air in the region is of extraordinarily high quality. But, to the continuing frustration of local environmentalists, the more they succeed, the more economically attractive their region becomes for polluting companies, since risk assessments and environmental impact assessments assume that a clean environment can tolerate more pollution.
For this reason, the practice of risk assessment may be tempered with another environmental policy making principle, implementation of the Best Available Technology (BAT). The principle of BAT argues that maintenance of environmental quality is a higher priority than minimizing pollution abatement costs. Rather than loading the environment to a predetermined acceptable dose and risk level, the BAT approach argues that every effort should be made to minimize environmental degradation.
Risk assessment is presently conducted separately on individual facilities, radionucleides, and chemical compounds. The process normally assumes that one risk does not interact with another. The interactive effects of compounds are frequently ignored. However, there are many examples of risk caused by such interactions, or synergistic effects. For instance, chlorine is added to public water supplies to kill bacteria. However, chlorine reacts with solids (suspended particulates) in water to create trihalomethanes, which are proven carcinogens.
Such complexity is not sufficient reason to reject the process of risk assessment, but it is reason to require that such interactions be identified and evaluated.
Environmental risks are often compared to those posed by existing background levels. This is most common in the field of radiation risk assessment. However, risk assessments are frequently used to argue for elevating levels of regulated substances just slightly over the existing background levels increase. For example, the background levels of radiation and dioxin in much of the world are now very much higher than a few decades ago.
At some point, perhaps in our past for many substances, it is reasonable to question whether or not background risk has itself become risky.
Risk assessment is a logical outgrowth of the 18th century Enlightenment: science was thought to be the means by which mankind could understand the natural laws of the universe, master nature, and engineer a perfect society. In this two hundred year old spirit, those who conduct risk assessments assume that the natural systems they investigate are orderly and sufficiently stable so as to be highly predictable. They assume that any minor variations in the biological systems they are evaluating will have insignificant consequences upon the final calculations of risk for that system.
Modern science is however reexamining many of its notions about the stability and predictability of complex systems in light of chaos theory. Chaos theory has focused its attention upon complex systems where minor perturbations may produce radical changes. The weather is a classic example. Minor changes in one region may have significant and unpredicted impacts half a continent away. This concept has given rise to the now famous concept of the "butterfly effect".
In chaos theory, the simple agitation of a butterfly could, under the right circumstance, affect the direction of the wind if we assume that the butterfly flew through a perfectly but precariously balanced weather system. The mild perturbation of the butterfly's wings could change the entire system. (This example is meant to be an exaggerated illustration of a principle, not a highly likely real world event.)
The general public has long had an intuitive grasp of the conclusions of chaos theory. It knows that an extremely low probability event can have disastrous consequences for the systems in which normal people live. Ordinary people are accustomed to observing dramatic changes in the often unstable and precariously balanced economic, social, and biological systems in which they live. These changes are often precipitated by small outside forces. Minor changes in interest rates impact business investment and employment. Small shifts in demographics, such as a slightly younger population, dramatically impact crime rates. New hunting and fishing technologies precipitate dramatic changes in wildlife or fish stock. Therefore, in calculating risk and accepting risk predictions, the public has intuitively embraced the concept of "the butterfly effect" - rooted in an awareness of the instability of the universe - while traditional scientists have assumed a more orderly, more predictable, and more manageable world.
Perhaps it is time for risk assessors to be more open about the inherent uncertainties in their work. They should begin to develop models which publicly acknowledge and quantify the potential impact of low probability but potentially devastating events, like nuclear power plant accidents.
A classic example of the clash of science and public perception occurs in the arena of comparative risks. Homicide, drug abuse, auto accidents, and suicide create enormous anxiety among the public. However, in the United States, all of these problems together cause fewer deaths yearly than does cigarette smoking. The daily world death toll from smoking is an estimated 8,200. In theory, the cost of eliminating Rational Risk Assessment, con't from p. 9 this risk is minimal as the problem is 100 percent preventable. But cigarette smoking has been, to a large degree, a culturally accepted risk.
Consequently, among European environ-mentalists there is relatively little attention directed toward eliminating the risks associated with smoking, while comparatively enormous time, energy and resources are invested in health issues associated with landfill pollution, high voltage electrical transmission lines, and food additives. In a world where environmental organization fund raising is partly dependent upon maintaining a high level of public concern about environmental health and safety, dispassionate analysis of risk and the comparison of risks is an essential, though potentially unpopular, ingredient of good policy making.
Risk assessment, for all of its scientific pretensions of objectivity, is still essentially a political process. It functions as part of a political process and its results reflect power relationships as much as "objective truth". Risk assessment works only where there is meaningful public participation in environmental decision making and where there are effective checks and balances placed upon scientific claims to the truth. Otherwise "risk assessment " can be used as a tool of technocratic rule: rule by a technically trained elite who are not responsible to the public, and not controlled by democratic processes such as checks and balances or elections.
There is an enormous temptation to escape from the time consuming and often tedious debates of democratic decision making and flee into the arms of technocracy. Recently ECOLOGIA hosted a group of visitors from the Former Soviet Union. After a two day workshop on an environmental decision making model for selecting clean up technologies, one of the participants noted that as a public official he would welcome such a "scientific approach" as it it would free him from making the final decision and insulate him from the complaints of the public and industry. He was disappointed to be reminded that the decision making model only presented options and their consequences. Policy makers still had the responsibility of choosing among the options.
Science is a neutral forum for determining facts, evaluating and comparing some of the consequences of specific decisions. To the degree that risk assessment can contribute rationality to the decision making process, it can be an important tool. It is not however the entire solution.