=======================Electronic Edition========================
RACHEL’S ENVIRONMENT & HEALTH WEEKLY #470
—November 30, 1995—
News and resources for environmental justice.
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MAKING GOOD DECISIONS
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
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[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.
Descriptor terms: risk assessment; decision making; hazard
assessment; chemicals; toxicity; immune system; nervous system;
genes; endrocrine system; reproductive system; developmental
damage; toxicity; ethics; cancer; carcinogens;