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#706 - Modern Environmental Protection--Part 3, 16-Aug-2000

Once in a while a really important new idea comes along -- or an
old idea gets applied in important new ways. Mary O'Brien's
proposal for "alternatives assessment" instead of "risk
assessment" falls into this category -- innovative and important.
No doubt I'm biased because our organization hired O'Brien so she
could find the time to write a book on this subject. The book has
just been published by MIT Press.[1] O'Brien's basic idea is
astonishingly simple but also delightfully subversive of the
status quo. Her idea is that we should all take a CONSUMER
REPORTS approach to decision-making. Just as the well-known
consumer magazine examines a range of available options before
recommending a particular toaster or TV, all decision-makers
(public AND private) should examine a full range of options
before committing to a new project or new technology. The
least-damaging option should be chosen. In other words, we should
look before we leap.

O'Brien's approach makes such good sense that you might think all
decision-makers would be using it already. But that's not how
decisions are made in the industrialized world. Instead of
examining a full range of alternatives, decision-makers generally
decide what they want to do, then they hire a risk assessor to
convince everyone that the damage they are about to do is
"acceptable." By the time damage becomes apparent, they're
hauling loot to the bank. At that point, stopping them is almost
impossible. The cumulative result of this "risk-based
decision-making" is a severely degraded and stressed global
ecosystem. To put it bluntly, the global ecosystem is being
shredded by people who are building roads, filling wetlands,
logging forests, damming rivers, vacuuming fish from the oceans,
overgrazing grasslands, depleting topsoil, wasting and polluting
water, and dumping persistent chlorinated chemicals, toxic
metals, greenhouse gases, and nitrogen into the environment on a
massive scale. Each of these damaging activities is justified and
deemed to be "acceptable" on the basis of a risk assessment.

Sometimes risk assessments are very formal, filling 1000 pages or
more with mathematical formulas and technical data. On the other
hand, most risk assessments are so informal that you might not
even recognize them as risk assessments -- they may consist of a
mere sentence or two. Examples: "Silt runoff will be kept within
acceptable limits by the use of hay-bale barriers, so our
construction project on the edge of the Bay will kill very few
fish." Or "Naturally-occurring chemicals in food cause more
cancers than this pesticide will cause, so it would be silly and
a waste of money to worry about the presence of this pesticide in
your cornflakes."

Risk assessment is the most powerful intellectual tool that the
poisoners and destroyers of the planet have ever invented. It is
their battering ram AND their camouflage. It provides "cover" for
just about any damaging activity that anyone might want to
undertake. Risk assessment is used to justify exposing workers to
toxic chemicals and radiation; to justify clearcutting and other
harmful practices in irreplaceable forests; to justify automobile
emissions and the resulting killer smogs; to justify allowing
silt and topsoil to escape into rivers and streams; to justify
cleanup standards for radioactive contamination and for chemical
dumps, accidents and spills; to justify dams; to justify suburban
growth and encroachment onto farmlands; to justify fishing and
hunting quotas; to justify contaminating our food with pesticide
residues and other additives; to justify destroying habitat
needed by endangered species; to justify "acceptable levels" of
industrial toxicants in our drinking water; to justify new road
construction in roadless areas... and on and on. In a nutshell,
for any particular activity, risk assessment asks (a) how much
damage will be caused, (b) to what degree will humans and
non-humans be "exposed" to the damage, and (c) will the local
consequences be "acceptable"? Naturally, what is "acceptable" is
a political judgment. If you ask the owner of a chemical factory
how much money should be spent to prevent cancer in a worker,
you'll get one answer. If you ask the same question of the
worker, you'll get a different answer. What is deemed
"acceptable" is a matter of raw political power. Thus risk
assessment is not a "scientific" exercise -- it is a highly
political mixture of prejudices, biases, guesses, estimates, some
scientific facts, and many ethical judgments -- all masquerading
as "objective" science.

Even the question, "How much damage will be caused?" is a
political question. The answer depends upon how hard you are
willing to look, what kinds of damage you are willing to
consider, and how much scientific ignorance you are willing to
acknowledge. The truth is, scientists can never figure out
whether pesticides on a child's cornflakes (for example) are
"safe" or "insignificant" because (a) there are dozens or
hundreds of adverse effects to consider, and -- if history is any
guide -- new ones will be discovered tomorrow; (b) the pesticide
effects will be added on top of whatever other stresses the child
may be experiencing (medical drugs, auto exhaust, paint fumes,
second-hand cigarette smoke, divorced parents, chronic ailments,
excessive ultraviolet radiation from the sun because of a
depleted ozone layer, and so on); (c) children (like all
organisms) have differing abilities to cope, and a unique history
of exposure to hazards; and (d) all organisms, like all
ecosystems, are simply too complex for science to understand
sufficiently to allow reliable prediction of effects.

In reality, risk assessments simply omit all these complexities
-- which is to say, they ignore the real world and thus are a
special brand of science fiction. Scientists (or journalists) who
assert that exposures to industrial chemicals are "harmless" or
"insignificant" are participating in a fraud because they are
pretending to know things that cannot be known. When a risk
assessor's work is used to expose people to unnecessary hazards
without their consent, it crosses the line and becomes grossly
immoral.

Risk assessment always asks the wrong question: it asks how much
damage is safe instead of asking how little damage is possible.
Furthermore, risk assessment conveniently never asks, "Is the
proposed activity needed?" It never asks, "Is the proposed
activity ethical?" It never asks, "What will be the cumulative
impact of this activity combined with all the other damaging
activities to which humans and non-humans are exposed at this
location?" And risk assessment never, ever asks, "Are there less
damaging ways to accomplish the same purpose?" On the other hand,
all these questions are central to an "alternatives assessment."
Thus alternatives assessment is wonderfully subversive because it
asks fundamental questions about "business as usual." Risk
assessment, on the other hand, simply greases the skids for
"business as usual."

Starting about 1975, industrialists hoped that risk assessment
would become the permanent key to imposing harmful decisions on
an unwilling public -- and for a couple of decades it seemed to
be working. Corporate risk assessors -- and a phalanx of
third-rate journalists transformed into highly-paid "risk
communicators" -- like to dress up in white lab coats and hang
stethoscopes around their necks, then accuse their critics of
being "irrational" devotees of "bad science." Monsanto, Dow
Chemical and other major polluters have spent hundreds of
millions of dollars promoting the idea that risk assessment is
the very definition of "good science." Harvard University houses
a polluter-funded "center" for risk assessment, which pumps out
an endless stream of shameless propaganda aimed at convincing the
American public that we all need to make more decisions based on
risk assessment, because risk-based decisions are "unbiased,"
"impartial," "neutral," "rational," and based on "sound
science."[2] Sound familiar? The NEW YORK TIMES maintains at
least one staffer who writes almost nothing but risk-based
propaganda on behalf of polluting industries.[4] In this, he
joins a long list of distinguished corporate toadies like John
Stossel, Gregg Easterbrook, Elizabeth Whelan, and Michael
Fumento.

U.S. Supreme Court justice Stephen Breyer went the next step in
his book, BREAKING THE VICIOUS CIRCLE , subtitled, "Toward
Effective Risk Regulation."[3] Judge Breyer suggested that we set
up a "small centralized administrative group, charged with a
rationalizing mission" within the federal government, with the
power to impose their risk-based decisions the public, democracy
be damned. Like religious fanatics, this risk assessment crowd
wants us to believe that they have found the truth and the way --the
only way. But really all they've found is a new way to
justify shredding the biosphere to make money. It's just a one
more scam to provide cover for traditional destructive behavior.
In her book, Mary O'Brien devotes sections to Why business loves
risk assessment, Why government agencies use risk assessment, and
Why many scientists live with risk assessment even though they
know risk assessment isn't mainly a scientific activity -- it is
mainly a political weapon wielded by the powerful to have their
way with the rest of us.

O'Brien's book is filled with provocative ideas. For example, our
government -- and many others, like the Harvard risk assessors[2]
-- recommend "comparative risk assessment" to rank environmental
problems from important to unimportant. The rationale is that we
don't have enough money to solve all our problems, so we should
spend our scarce dollars on the most important. O'Brien
challenges that thinking: "It is noteworthy that
comparative-risk-assessment processes rank environmental
problems. It would be just as logical to rank which behaviors are
causing the greatest environmental problems, or who is causing
the greatest environmental problems, or which social arrangements
allow or encourage people to cause environmental problems. By
focusing on environmental problems rather than on problematic
behaviors, problematic people, or problematic social
arrangements, the comparative-risk-assessment group can pretend
that the problems just 'happened' and that no identifiable
individuals or businesses caused them." (pg. 121)

O'Brien suggests that, in a democracy, all businesses and
government agencies should be required to explore, on paper, and
in understandable language, their options for causing the least
possible environmental damage. She says, "All potentially
environmentally degrading activities, public or private, should
be subject to public scrutiny of alternatives. The public
deserves to know that those who pollute, extract, consume, emit,
incinerate, or abandon are aware of their technological options
for minimizing disturbance of the environment."(pg. 122) But of
course this won't happen any time soon because, as O'Brien says,
"If you wanted to get approval to undertake a particular
hazardous activity, would you want people asking big questions
about the activity? Would you want people to think that the
hazards or the potential risks were unnecessary? Alternatives
assessment threatens the status quo. Alternatives assessment can
make social change seem both desirable and possible."(pg. 136)

Is risk assessment 100% bad? Not necessarily. In a thorough
analysis of a full range of alternatives, risk assessment might
play a role. It is risk assessment of only one or a few options
that O'Brien wants to eliminate.

Please urge your local library and bookstore to order MAKING
BETTER ENVIRONMENTAL DECISIONS from MIT Press.[1] Starting this
fall, Mary O'Brien will be available to give a talk, debate a
risk assessor, lecture at your local university, or consult with
your citizen group or your government, to help discover how
"alternatives assessment" can improve decisions in your area of
interest. She can be reached by E-mail: mob@darkwing.uoregon.edu.

--Peter Montague (National Writers Union, UAW Local 1981/AFL-CIO)

=====

[1] Mary O'Brien, MAKING BETTER ENVIRONMENTAL DECISIONS; AN
ALTERNATIVE TO RISK ASSESSMENT (Cambridge, Mass.: MIT Press,
2000). ISBN 0-262-15051-4.

[2] See for example David Ropeik, "Let's Get Real About Risk,"
WASHINGTON POST August 6, 2000, pg. B1.

[3] See REHW #394. Stephen Breyer, BREAKING THE VICIOUS CIRCLE;
TOWARD EFFECTIVE RISK REGULATION (Cambridge, Mass.: Harvard
University Press, 1993; paperback edition 1995); ISBN 0674081153.

[4] See for example John Tierney, "Tracing the Toxins to Your
TV," NEW YORK TIMES August 18, 2000, pg. A25.