=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #204
—October 24, 1990—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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RISK ASSESSMENT–PART 3: ALTERNATIVES TO RISK ASSESSMENT.
Quantitative risk assessment is now widely used throughout
government and industry to “prove” that a proposed chemical
exposure will produce only “acceptable” damage to humans. For
example, a quantitative risk assessment for a proposed
incinerator will “prove” that “only” one person out of a million
exposed people will be killed each year by air pollution from the
incinerator. No scientists actually believe that humans have
sufficient knowledge to measure risks from toxic chemicals
accurately or precisely or completely. For example, the U.S.
Environmental Protection Agency’s Science Advisory Board recently
said that risk analyses “always will be imperfect tools” and “No
matter how much the data and risk assessment techniques are
improved… EPA’s judgments [based on risk assessment] will
entail a large measure of subjective judgment.”[1]
This inherent uncertainty in risk assessment means that clever
people can manipulate data, and can manipulate unspoken
assumptions, to achieve any quantitative result they choose. In
fact, it is common for risk assessors to select the goal that
their risk assessment is supposed to achieve (onein-a-million is
a common goal), then to manipulate the data and assumptions to
come up with the “right” answer. The result is usually expressed
as a single number and such numbers look very precise and
scientific even though they may be based only on estimates or
guesses, or may even have been fabricated.
For the past six years, Mary O’Brien has edited the JOURNAL OF
PESTICIDE REFORM and has served as staff scientist of the
Northwest Coalition for Alternatives to Pesticides in Portland,
Oregon. For six years she has seen risk assessments used by
scientists employed by polluters to justify exposing people to
toxic chemicals.
“Worker inhalation and absorption of workplace toxics is approved
via risk assessment,” she says. “The spraying of pesticides on
schoolgrounds, roadsides, over urban areas and forests, and on
the nation’s food supply is dubbed acceptable via risk
assessment. The degradation of our drinking water supplies,
aquifers, and air is approved via risk assessment.”
Ms. O’Brien believes that risk assessment should be put on the
back burner and, in its place, we should substitute a formal
search for alternatives. Instead of asking “How much human health
damage is acceptable?” we should start asking “How quickly can we
install or use practices that will result in the least use of,
and exposure to, toxic chemicals?”
The basic goal of a risk assessment is to evaluate the potential
consequences of a decision, recognizing that much necessary
information is not available and may never become available.
Numerous wise approaches are available to replace risk
assessment, and they must often be used in combination with each
other:
1. Qualitative risk assessments. These methods involve looking at
worst-case environmental and social consequences of inadequate
information, missing information, non-scientific information
(complaints by workers about their experiences on the job, for
example), epidemiological information, and suspicions about
cumulative effects. A “chemical profile” that looks at all
aspects of a chemical (known and unknown) can be extremely
revealing. (See RHWN #169.) Instead of spending vast sums on risk
assessment for particular chemicals, perhaps a review of
available information is sufficient to say, “This chemical seems
to cause problems among laboratory animals and workers. We don’t
know very much about its mechanisms of toxicity, we’ll never know
what it does to people in combination with the hundreds of other
chemicals they’re exposed to, so we’ll never be able to produce a
convincing risk assessment. Therefore instead of producing a
scientific sham risk assessment let’s seek alternative ways of
getting the job done (whatever the job is), reducing or even
eliminating use of this potentially harmful chemical.”
2. Labeling products and processes with all toxic chemicals used.
If all workplace processes are labeled (every pipe, every vat,
every drum, as is required by the New Jersey Worker and Community
Right to Know Law), and all consumer products are labeled with
their toxic ingredients, citizens can at least make informed
choices about what they want to expose themselves to. Prop 65 in
California requires that any person who knowingly and
intentionally exposes another person to a carcinogen, or to a
chemical known to cause reproductive hazards, must give clear and
reasonable warning to the person exposed. Let the consumer be
informed.
3. Some chemicals can be phased out by regulating particular
compounds or particular processes. DDT has been banned for sale
in the U.S.; Sweden has given its pulp and paper mills a deadline
for near-zero discharge of chemical compounds containing
chlorine; if the “Big Green” initiative passes in California this
November, use of carcinogenic pesticides on California food will
end within 5 years. Just say “no” to some chemicals.
4. Require honesty about ignorance in quantitative risk
assessments. Where quantitative risk assessments are used, they
could be supplemented by formal statements about their
shortcomings. Such statements could include standards that have
been set elsewhere to control this chemical; the kinds of
scientific tests that have not been done on a chemical (for
example, studies of chronic nerve damage); whether infants, old
people, and chemically sensitive people were considered in the
assessment; whether degradation byproducts of the chemical were
considered in the assessment (for example, DDT breaks down in the
environment to a chemical called DDE, which is more toxic than
DDT); what is not known about chemicals in combination with each
other. People need to know that, with toxic chemicals, the
unknowns are much larger than the knowns.
5. Require an official search for alternatives to toxics. Often,
a formal search for alternatives to toxics will make a risk
assessment unnecessary. “Anyone who sees chlorine-free paper
products (e.g., magazines, copy paper, toilet paper, tampons)
available in Sweden and Austria realizes the absurdity of
estimating how many dioxin-laden fish caught below a
chlorine-using pulp mill constitute ‘acceptable risk’,” says Mary
O’Brien.
“The first step of admitting that it would be desirable to reduce
use of pesticides and other toxics is generally the hardest for
most agencies or industries,” she says. But getting agencies and
industries to state such a preference is crucial. Once we reach
agreement that toxics use reduction is desirable, then the formal
search for alternatives can be initiated and we can stop relying
on the narrow, deceptive “science” of quantitative risk
assessment.
–Peter Montague, Ph.D.
===============
[1] REDUCING RISK: SETTING PRIORITIES AND STRATEGIES FOR
ENVIRONMENTAL PROTECTION (Washington, DC: Science Advisory Board
[A-101], U.S. Environmental Protection Agency [401 M St., Nw,
Washington, DC 20460], September, 1990, pg. 16. This 26-page
summary report is available upon written request from the Science
Advisory Board at the address given (don’t forget the A-101); and
be sure to ask for the three separate Appendices as well. To
understand the federal government’s viewpoint toward risk
assessment, you might want to get the Council on Environmental
Quality’s book RISK ANALYSIS: GUIDE TO PRINCIPLES AND METHODS FOR
ANALYZING HEALTH AND ENVIRONMENTAL RISKS. Available for $17.50,
plus $3.00 shipping, from National Technical Information Service
(ntis): phone (703) 487-4650. Ask for document Pb 89-137772. [We
have taken material from two articles by Mary O’brien writing in
the JOURNAL OF PESTICIDE REFORM (JPR), Vol. 8 No. 1, pgs. 7-13
and Vol. 10, No. 1, pgs. 2-6. We urge readers to subscribe to
JPR: individuals, $15/yr; institutions, $25/yr from: Northwest
Coalition for Alternatives to Pesticides, P.O. Box 1393, Eugene,
Or 97440. Back issues are available for $3 each, or $10 for a
year’s worth..”
Descriptor terms: risk assessment; journal of pesticide reform;
mary obrien; workers; occupational safety and health; labelling;
chlorination; chlorine;