by Mary O'Brien, Ph.D.

[Editor's note: Most of us encounter risk assessment in the context of a dispute over waste disposal technologies and/or toxic exposures. But during the past 15 years risk assessments have come to be used throughout our society to justify all sorts of decisions that have been made for narrow purposes. Risk assessment is now routinely used to justify decisions about land use and resource allocation in the western states. The argument that Dr. O'Brien develops, that it is time to consider "alternatives assessment" instead of "risk assessment" as a guide for decision-making, applies to toxics as well.]

Much of my work over the last ten years has been with alternatives to use of toxics: pesticides throughout society, chlorine in the pulp and paper industry, and currently the potent ozone depleting fumigant, methyl bromide.

During these years, I have come to hate the use of risk assessment, which is used obsessively in the U.S. to determine how much of a toxic substance will be dumped into the world: How much pesticide will be allowed on the apples you eat; how much dioxin a company like Stone Container can dump in the Clark Fork River; the size of an air pollutant permit one company can buy from another in a polluted urban area. Now the U.S. Environmental Protection Agency is aggressively teaching other countries like Mexico and the Ukraine how to do quantitative risk assessment so that everyone will use the same language for global free trade in toxics.

The whole point of risk assessment is to determine how much damage people will be permitted to do in the world. The alternative, largely ignored, is to figure out how LITTLE damage people can do to the world.

But risk assessment is not confined to toxics, and I want very briefly to describe five behaviors characteristic of risk assessors and then relate these to what risk assessors do in the world of natural resources and wildlands. These can be risk assessors in the Forest Service, Bureau of Land Management, Sierra Club, Audubon Society, or other agency or big environmental group.

1. Toxics risk assessors act as if they know what damage a toxic chemical does, and as if they can, on the basis of this knowledge, determine some safe or "insignificant" level of exposure to the toxic. But of course they don't know this. They may know what kind of chronic damage or birth defects a single chemical causes in a genetically pure line of healthy laboratory rats. They generally have no information on whether it causes immune suppression, endocrine disruption, or nerve damage in infants; or chronic damage in people who already are damaged in some other way.

2. Toxics risk assessors focus on one chemical at a time. When I recently asked the Director of the National Institutes for Environmental Health Sciences about the possibility of switching the focus of the National Toxicology Program from testing a handful of individual chemicals for cancer a year to looking at types of mixtures of chemicals faced by people living near multiple industries or incinerators or hazardous waste dumps, he indicated that studying mixtures of chemicals is "too hard." The problem, however, is that we and wildlife are exposed to mixtures of chemicals and indeed are born with them, our mothers having passed on many to us.

3. Toxics risk assessors focus on whether the world can withstand a particular activity. The assessors try to figure out, for instance, whether you will survive if Stone Container uses chlorine to make cardboard blinding white. They may ask whether fish at the end of the mill's nine-mile "mixing zone" will be able to reproduce.

4. Toxics risk assessors decide what levels of risk and damage and killing are acceptable for other people. But can anyone decide an acceptable risk for you? Isn't it premeditated murder to give permits to industries with the estimate that one in 100,000 people will get cancer? Other, perhaps more vulnerable, species are seldom considered in the permits.

5. Toxics risk assessors focus on the risks and damages caused by business-as-usual, not business-as-it-could-be. The alternative to determining how much damage people will be permitted to do in the world is to determine how little damage people COULD do in the world.

Let's look at the analogous activities of risk assessors in the world of wildlands, wildlife, and natural resources, and what they could do differently.

1. Land management risk assessors assume they know what damage clearcutting or road-building or grazing or pesticide spraying or mining does to an ecosystem's web of life. Do Forest Service risk assessors know what is happening to bats on lands they oversee? Do they know the needs of rare butterflies on that land? Do they know what organochlorines are doing to reproductive success of Peregrine Falcons? Land managers and users need to admit they don't know enough to say what human activity is safe. They can only have an inkling of the damage humans do. They don't know what the rare butterflies and the bats need. They don't even know what butterflies and bats are out there.

2. Land management risk assessors focus on one activity, one timber sale, one stream, maybe one watershed, or one Congressional bill at a time. Do the risk assessors know what happens when a watershed is subjected to grazing and clearcutting and pesticides and road-building at the same time? Do they know what happens when Peregrine Falcons are faced with reduction in prey and loss of solitude and organochlorines in the food chain, all at once? Land managers and users need to focus on cumulative effects and the interdependence of various elements of the ecosystem. Cumulative effects are often impossible to quantify; and risk assessors get nervous when they can't reduce decisions to numbers. Yet, effects are cumulative.

3. Land management risk assessors focus on whether the land can withstand a certain action. For a year and a half, the Wallowa-Whitman National Forest convened a citizens committee to suggest management of the Snake River. The committee was called the Limits of Acceptable Change Committee. How many more jet boats could the river stand? Could airports fit within the "limits of acceptable change?" How many domestic sheep allotments are compatible with Bighorn Sheep in Hells Canyon? What is the minimum acreage of roadless areas in Montana that must be protected to constitute a Wilderness bill? Rachel Carson asked a different, more appropriate question in SILENT SPRING: "Who would want to live in a world which is just not quite fatal?" Land managers and users need to focus on what the natural world needs and what our options are for living in accordance with those needs. As Aldo Leopold wrote in SAND COUNTY ALMANAC, "The practices we now call conservation are, to a large extent, local alleviations of biotic pain. They are necessary, but they must not be confused with cures. The art of land doctoring is being practiced with vigor, but the science of land health is yet to be born."

4. Land management risk assessors assume they can define acceptable damage for society. In the March 1992 edition of the Northern Region Forest Service paper called "Our Approach to Sustaining Ecological Systems," the Forest Service says that the Desired Condition (DC) of a landscape at any scale must account for the goods, services and amenities desired by society." Who is "society?" What "society" demands salvage logging? What amenities will our children want? The risk assessors in some environmental groups ask, "What level of conservation is acceptable to our members? To our granting foundations and corporations?" Land managers need to face their responsibility to advocate for the land and educate the public regarding the benefits of behaving well toward the land. Instead of acting as if they know what da-mage is acceptable to society, they need to sell the public and Congress on the social, environmental, spiritual, and economic benefits of wildlands.

5. Land management risk assessors focus on business-as-usual rather than business-as-environmentally-responsible. Again, risk assessors do not look at how our society might treasure, and benefit from forests that are whole and wild. They do not look at the best forestry that could be done. They do not present the uses of our National Forests that would be least damaging, most protective, most restorative. Instead, they look at business-as-usual: They uphold timber, grazing, and mining interests. Land managers need to constantly search for the most environmentally responsible alternatives for behaving on public and private lands. The Forest Service and environmental organizations need to go beyond looking at incremental improvements in mining, grazing, predator killing, and tree cutting. They need to systematically consider what behaviors are truly compatible with diverse plant life, clean water, recovering fish populations, and silence. In all of our work with the Northern Rockies lands and peoples, we need to reject the process of figuring out the limits of acceptable degradation. We need to reject the current dominant role held in our society by risk assessment and replace it with alternatives assessment. We need to take the high scientific, ecological, political, and moral ground and advocate for the best possible behaviors of people toward the Earth. Always.

This article is reprinted, with permission, from WILD EARTH Winter 1992/93. WILD EARTH is published quarterly by The Cenozoic Society, P.O. Box 492, Canton, NY 13617; telephone (315) 379-9044. Annual subscription to WILD EARTH: $25.00.

Mary O'Brien has a Ph.D. in botany. From 1983 to 1990 she served as staff scientist for the Northwest Coalition for Alternatives to Pesticides in Eugene, Oregon and during the same period she edited the Coalition's quarterly JOURNAL OF PESTICIDE REFORM. She is president of the board of directors of the international Pesticide Action Network (PAN) in San Francisco, CA. Later this year, Dr. O'Brien will join the staff of Environmental Research Foundation as staff scientist.

Descriptor terms: risk assessment; stone container; clark form river; oregon; montana; or; mt; epa; mexico; ukraine; niehs; chlorine; dioxin; species loss; wildlife; land use planning; land use management; organochlorines; cumulative effects; snake river; aldo leopold; sand county almanac; usfs; usda; us forest service; wild earth;