Risk Assessment

The logical method and form flatter that longing for certainty and

for repose which is in every human mind. But certainty generally

is an illusion, and repose is not the destiny of man.

Oliver Wendell Holmes

Public health concerns are usually at the center of most environmental problems. Determining the health risk of environmental pollution is no easy task for it calls for a collaborative blending of medicine, science, engineering, economics and politics—not an easy alliance. Health Risk Assessment is the tool usually used by both government and industry as a supposedly neutral, scientific approach to quantify environmental risks to public health. The goal of Health Risk Assessment is to establish “acceptable” health level of pollution exposure which levels then serve as critical standards of judgment for continuing or proposed projects and cleanups. However, Health Risk Assessment is not a neutral or a scientific tool, but is inherently biased and political in nature.

(1) Health Risk Assessment is a subjective, arbitrary, and discretionary political process, rather than an objective and scientific activity. As such it cannot guarantee that the public health will be protected. Where the acceptable level of exposure is drawn and what constitutes a public health risk depends entirely on who is doing the study. Alvin Alm of the Environmental Protection Agency in Advances in Health Risk Assessment for Systemic Toxicants and Chemical Mixtures comments that “Risk assessment is not strictly a scientific procedure. Questions of personal politics and of what might be called scientific ideology arise constantly. The process of assessing risk is inherently uncertain. . .because the results depend heavily on the procedures and assumptions used. This inescapable fact gives rise to fears that those procedures and assumptions can be juggled for political ends” Walter Rosenbaum of the University of Florida notes: “Discretionary judgment also permeates the process of determining acceptable risks, which invites pressures and counter pressures from contending sides struggling to influence official decisions to their advantage. The language of the law may conceal it, but determining acceptable risk is ultimately an intensely political affair.” (Environmental Politics and Policy) For example, Rosenbaum points out how standards of acceptable risks constantly change from Presidential administration to presidential administration depending on the political proclivity of the current regime. Each change or position had its own set of expert scientists to support it. The point is that, depending upon what scientists one consults, the results differ. The cause of these differences is that there exists expert uncertainty as to what compromises human health and that there are a multitude of risk criteria allowed f which yield different and contradictory results. William Ruckleshaus, a past administrator of EPA gave a salient example of the discretionary and arbitrary nature of the risk assessment process: “I just had an eight-hour briefing on fine particulate standards. . . . Our Scientists told me we can defend any standard between 150 and 250 parts per million. So pick a number.” (Quoted in Rosenbaum, p. 142) We should not hold our health hostage to the arbitrary and subjective political process we call Health Risk Assessment.

(2) Health Risk Assessment does not exclude the bias and prejudice of those doing the study. It is estimated “that in a normal risk assessment around 50 opportunities exist for . . . scientists to make discretionary judgments.” (Rosenbaum, p.153) A study by political scientists t Thomas M. Dietz and Robert W. Rycroft, who interviewed some 228 health risk assessors, found that “place of employment is significantly linked to differences in . . .the use of both risk and cost-benefit analysis” and that the health risk process is characterized by “a weakening of disciplinary perspectives and a strengthening of viewpoints based on politics and ideology.” (The Risk Professionals) Physicist Harvey Brooks observes: “The more an issue is in the public eye, the more expert judgments are likely to be influenced unconsciously by preexisting policy preference or by supposedly unrelated factors such as media presentation, the opinions of colleagues or friends or even the emotional overtones of certain words used in the debate.” (Science, Technology and Human Values.) Similar conclusions about the arbitrariness of health risk assessments have been reached by the National Research Council, Commission on Life Sciences, and the Committee on the Institutional Means for Assessment of Risks to Public Health. There is no way to prevent this social, economic, and political bias from entering risk assessment. A socially neutral science in the realm of health risk assessment is a myth. When there is ambiguous or mixed data, “experts often will select the viewpoint congenial to their political, social, or economic convictions.” (Rosenbaum, P. 262) Such arbitrariness cannot guarantee that the public health will be protected. We should not hold our health hostage to a process that inherently included the biases of those doing the study.

(3) Risk Assessment does not guarantee that significant reduction of pollution will occur in the environment. The goal of environmental regulation should be the eventual elimination of environmental pollution and resultant threats to public health. For example, the National Environmental Policy Act (NEPA) has as it purpose: “to prevent or eliminate damage to the environment and to promote health.” If we are to be true to the intent of NEPA to protect the public’s health, we should significantly minimize, if not eliminate, public exposure to toxic pollutants. The goal should be the prevention of health problems before they occur. Unfortunately, as we know, health risk assessment can actually sanction the continuation of pollution in the environment through the allowance of so-called “acceptable” levels of exposure. This is a particularly pernicious result in that, in many cases, the substances to which people are involuntarily exposed such as heavy metal pose sever potential health risks. Barry Commoner of Queen’s College offers this conclusion: “In sum, the original fault embedded in the U.S. system of environmental regulation—that it attempts the inherently futile task of controlling rather than preventing pollution—has itself spawned a series of new faults that erode the integrity of science, the regulatory process, and public policy. The environmental failure has been very costly, not only in money but in burdening the still unsolved environmental crisis with a heavy heritage of poor public policy disguised as science and poor science disguised as policy. “ (Making Peace with the Planet.) We should not countenance a method such as Health Risk Assessment which sanction continued environmental degradation.

Summary

The goal of environmental policy should be the prevention of pollution or removal of existing pollution. If a substance is harmful to human health or the environment it should be reduced to the maximum possible limit. Health Risk Assessment is inimical to this goals for its allows for so-called “acceptable” level of pollution. Would we allow as social policy acceptable level of child abuse? Are there acceptable levels of assault? There should be no acceptable levels of environmental degradation.