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#470 - Making Good Decisions, 29-Nov-1995

Risk assessment is one way of making decisions, but it is not the only
way, and it is not the best way.[1] Furthermore, risk assessment as
usually practiced is unethical.

Risk assessment has been described by the National Academy of Sciences
(NAS) as a four-step process.[2]

STEP 1: HAZARD IDENTIFICATION. This step is supposed to estimate
chemical damage from acute (single dose), subchronic (a few doses), or
chronic exposures for each possible toxic endpoint. Toxic "endpoints"
include cancer, damage to organs (liver, kidney, heart, etc.),
developmental disorders, damage to the immune system, central nervous
system, reproductive system, and genes. Because organisms (whether
hamsters or people) react differently at different stages of
development, particularly while in the womb, dozens of "endpoints" must
be considered. In actual practice, most endpoints are simply ignored.

STEP 2: DOSE-RESPONSE ASSESSMENT. Dose-response assessment means
determining what damage, and to which bodily systems, will occur as the
dose of a chemical increases. Most people are familiar with the concept
of dose-response; think of the effects from drinking one, two, or three
glasses of wine. In general, greater dose leads to greater effect.
Usually assessing dose-response for a chemical requires estimating
("extrapolating") from data about laboratory animals, who have been
given high doses, to effects in humans who typically receive low doses
from environmental exposures. There are many different ways of
"extrapolating" from high-dose animal data down to low-dose human
estimates.

STEP 3: EXPOSURE ASSESSMENT. Exposure assessment tries, or should try,
to determine how much of a chemical is absorbed from all sources.
Example: if the chemical is a pesticide, exposures might occur through
food, water, air, and perhaps even skin, through home and occupational
uses. (In practice, many sources of exposure are usually ignored.)

STEP 4: RISK CHARACTERIZATION. Ideally, risk characterization takes
information from hazard assessment, dose-response assessment, and
exposure assessment, then adds information about the characteristics of
the affected population --How old are they? Are they generally
malnourished? Overweight? --and combines it all together to determine
an estimate of hazard (called "risk"). (In practice, the
characteristics of a particular population are usually ignored and
averages are used instead.) Hazard (called "risk") is expressed as a
probability of a particular kind of harm to a specified group of people
during a stated period of time. For example, a typical estimate of
"risk" might be expressed this way: a particular group of people is
expected to endure one additional cancer for every 100,000 people, over
and above the normal risk of cancer, as a result of chronic exposure to
some toxic chemical in their drinking water during their lifetimes of
70 years.

Despite the NAS's idealistic description of risk assessment, the
process is deeply flawed and subject to abuse.

** RISK ASSESSMENT IS INHERENTLY MISLEADING: In actual fact there are
no agreed-upon ways for assessing nervous system damage, immune system
damage, or damage to the genes.[3] Furthermore, science has no way to
evaluate the effects of exposure to several chemicals simultaneously.
Because everyone in the real world is exposed to multiple chemicals
simultaneously, risk assessment is never describing the real world, yet
almost always PRETENDS to describe the real world. Risk assessment
pretends to determine "safe" levels of exposure to poisons, but in fact
it cannot do any such thing. Therefore, risk assessment provides false
assurances of safety while allowing damage to occur. It is therefore
inherently misleading.

** RELIANCE ON RISK ASSESSMENT HARMS DEMOCRACY: Because risk assessment
is a mathematical technique, most people cannot understand, or
participate in, risk assessments. Therefore, reliance on risk
assessment for decision-making harms democracy because most people are
excluded from the process.

** A BETTER WAY OF MAKING DECISIONS IS AVAILABLE: To assure that all
viewpoints are brought to the table, we should not rely on risk
assessment for decision-making. Instead, we could employ a decision-
making technique that was described in the National Environmental
Policy Act (NEPA) of 1969, a federal law. NEPA requires that, before
certain decisions can be made, all reasonable alternatives must be
examined. If this approach is taken, then the public can get involved
in describing and discussing all reasonable alternatives. In such a
process, all viewpoints can be aired. Cultural values, historical
perspectives, and local concerns can all be brought into the decision,
along with issues of technology, costs, and benefits. People can look
at all the alternatives and can decide which one they prefer. The
process of thinking about alternatives is healthy for a community --it
helps people visualize the future that they want for themselves and
their children. Risk assessment suppresses such discussions.

** NO RISK IS ACCEPTABLE IF IT IS AVOIDABLE: When people are examining
a full range of alternatives, they have an opportunity to apply the
principle that, "No risk is acceptable if it is avoidable." However,
when people are merely doing a risk assessment, this principle cannot
come into play. A risk assessment never reaches the conclusion that a
risk is avoidable because risk assessment NEVER asks whether a
particular risk can be avoided. That is simply not a question that risk
assessment asks.

An example will show the difference between these two approaches (risk
assessment vs. examining all the alternatives): In some communities, a
decision has been made (often without any public input) to burn solid
waste. This decision has then been justified by a risk assessment. A
risk assessor is called in to show that the incinerator will "only"
harm one in a million people living nearby. Because the harm is so
"small," the incinerator is deemed "acceptable."

This is a typical use of risk assessment, to justify a decision that
was made by lawyers, financial analysts, bankers, corporate officials,
and elected officials. Often, such a decision is announced after the
fact, and then a risk assessment is completed to "prove" to the public
that such a decision is "acceptable."

Another way of approaching an incinerator would be to step back and
ask, "What is the problem we are trying to solve here?" One answer is
"the problem of solid waste" or perhaps even "use and disposal of items
that are not biodegradable."

Then the question becomes, what are the different ways of solving such
a problem? Here the public will have a great deal to say, and the
search for an answer can be a model of democracy. For some portion of
solid waste, recycling and reuse are obvious alternatives to
incineration. Separating out the toxic materials, and landfilling the
remainder, is another alternative. Some communities have even banned
certain kinds of consumer products because they are so difficult to get
rid of without creating dangers. Batteries that contain mercury are one
example; certain plastics are another example. Obviously there are many
alternatives to examine, including some alternatives that involve
asking people to consider changing their own behavior.

Once the various alternatives have been described, then risk assessment
could be applied to each alternative, as one part of a decision-making
process.

** RISK ASSESSMENT FAILS TO EVALUATE BENEFITS: Another advantage of
"examining all the alternatives," compared to risk assessment is this:
Risk assessment does not examine benefits, but "examining all the
alternatives" does. Naturally, when people make a choice, they want to
balance the disadvantages AND the advantages, the costs AND the
benefits. Risk assessment merely assesses the costs (the "risks") of
one proposal and asks whether those costs are "acceptable" or not. But
people in the real world don't just want to know whether the "costs"
are acceptable --they also want to know whether the "benefits" are
sufficiently desirable. Assessing all the alternatives will allow
people to discuss benefits as well as costs.

** RISK ASSESSMENT OF ONE OR A FEW CHOICES IS UNETHICAL: The
environment is being harmed and needs to be protected. Therefore,
ethical considerations require us to try to harm the environment as
little as possible. Risk assessment does not ask the question, "What is
the least harm we can do?" Instead, risk assessment asks, "Will the
damage we are going to do be acceptable?" To provide an ethical
framework for decision-making, we need to ask, "Which alternative will
bring sufficient benefits AND minimize damage to the earth?" If a
decision has not been made by examining all available alternatives and
then selecting the least-damaging alternative, the decision is not an
ethical one. Risk assessment as commonly practiced is unethical because
it excludes discussion of reasonable alternatives, including least-
damaging alternatives.

In sum, in the recent past, risk assessment has often been used to
impose bad decisions on people-of-color communities, on indigenous
people, and on communities that lack political power. Even when risk
assessment is used for legitimate purposes, it falls short as a
decision-making technique because it does not consider benefits or
alternatives; it only evaluates "risks" and furthermore it only
evaluates some of the "risks." Finally, it can never evaluate the
hazards of multiple exposures.

The main decision-making tool that we should rely on is "looking at all
the available alternatives" and having a full public discussion of the
costs AND THE BENEFITS of those alternatives. This approach can engage
the community in discussion of what is desirable and what is important,
not merely what is an "acceptable risk." In an open, democratic
decision-making process, risk assessment might play some role in
helping people evaluate a full range of alternatives, but it should
certainly never be the only decision-making technique, and it should
never be applied to a single choice or to a narrow range of choices.

Unless we search for least-damaging alternatives, our decisions cannot
be ethical ones. A decision made by examining the risks of a single
alternative, or of a narrow range of alternatives, can never be an
ethical decision. Protecting the environment requires us to examine all
the alternatives in an open, democratic process, examine all the costs
and all the benefits, and then choose the least-damaging alternative.

--Peter Montague

=====

[1] Thanks to Tom Goldtooth of the Indigenous Environmental Network
(IEN), and to Paul Connett of St. Lawrence University, who expanded our
thinking about risk assessment. Credit for the main ideas in this
discussion of decision-making belongs to Mary O'Brien, who nevertheless
bears no responsibility for the way those ideas are presented here.

[2] National Research Council, RISK ASSESSMENT IN THE FEDERAL
GOVERNMENT: MANAGING THE PROCESS (Washington, D.C.: National Academy
Press, 1983).

[3] See Anna Fan, Robert Howd, and Brian Davis, "Risk Assessment of
Environmental Chemicals," ANNUAL REVIEW OF PHARMACOLOGY AND TOXICOLOGY
Vol. 35 (1995), pgs. 341-368.

Descriptor terms: risk assessment; decision making; hazard assessment;
chemicals; toxicity; immune system; nervous system; genes; endocrine
system; reproductive system; developmental damage; toxicity; ethics;
cancer; carcinogens;