=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #337
— May 13, 1993 —
News and resources for environmental justice.
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Environmental Research Foundation
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RISK ASSESSMENT IN THE NORTHERN ROCKIES
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;