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May 27, 1999
THE WANING DAYS OF RISK ASSESSMENT
Risk assessment is a decision-making technique that first came into use during the presidency of Jimmy Carter, who was trained as a nuclear engineer. At its best, risk assessment is an honest attempt to find a rational basis for decisions, by analyzing the available scientific evidence. In theory it is still an attractive ideal -- to make rational decisions based on scientific evidence -- because in principle it should allow diverse parties to agree on what needs to be done. However, 20 years of actual practice have badly tarnished the ideal of risk assessment and have sullied the reputation of many a risk assessor.
History of Risk Assessment
During the late 1960s it slowly became clear that many modern technologies had far surpassed human understanding, giving rise to byproducts that were dangerous, long-lived, and completely unanticipated. A book-length report issued by the White House in 1965 began with a letter signed by President Lyndon Johnson, who said, "Ours is a nation of affluence. But the technology that has permitted our affluence spews out vast quantities of wastes and spent products that pollute our air, poison our waters, and even impair our ability to feed ourselves."[1] The 1965 White House report identified numerous major sources of environmental contamination: municipal and industrial sewage, animal wastes, municipal solid wastes, mining wastes, and "unintentional releases," which included automobile exhausts, smoke stack emissions, pesticidal mists, and agricultural chemicals draining into waterways, among others. The main report contained "subpanel reports" on soil contamination, the potential for global warming by carbon dioxide, the effects of chlorinating wastes, the health effects of environmental pollution, and "the effects of pollutants on organisms other than man."
In 1969, the U.S. Secretary of Health, Education and Welfare issued another book-length report on "Pesticides and Their Relationship to Environmental Health." The report said, "Recent evidence indicates our need to be concerned about the unintentional effects of pesticides on various life forms within the environment and on human health. It is becoming increasingly apparent that the benefits of using pesticides must be considered in the context of the present and potential risks of pesticide usage. Sound judgments must be made."[2]
Therefore by the mid-1970s it was obvious even to journalists and politicians that industrial technology had a massive dark side. Technical mastery of natural forces was leading not to safety and well being but to a careless and accelerating dispersal of dangerous poisons into the biosphere with consequences impossible to predict.
During the 1970s, in response to a decade of disturbing reports and revelations, a vast "environmental movement" developed, made up of citizens concerned about one place or another -- their dinner table, the playground in their neighborhood, the river running through their town (often the source of their drinking water). They demanded reforms. Congress reacted by writing laws the size of a telephone book and by creating new agencies and departments to issue enforceable regulations.
As all the early official reports make clear, in those days environmental contamination was viewed through the twin lenses of engineering and traditional toxicology. Traditional toxicology maintains that "the dose makes the poison" -- meaning that everything is poisonous at a high enough dose, and you can prevent poisoning by giving a low enough dose. The engineer seeks to develop a numerical formula that will give the desired result time after time.
Blended together, these views gave rise to the idea that the nation merely needed to set numerical "standards" for the discharge of industrial poisons into the environment. The world's capacity to absorb toxicants would be discovered by scientific analysis, toxicologists would determine the safe dose, and engineers would fine tune the nation's industrial apparatus to deliver just that dose and no more. At least that was the theory.
Unfortunately, there was one key element missing from this prescription: pollution pays handsomely. In the short run, corporations that dump their toxic wastes into a river, or bury them in the ground, make much more money than corporations that sequester and detoxify their wastes at great expense. Therefore, a political struggle of enormous proportions ensued. On one side, the petrochemical giants (such as Dow, DuPont, and Monsanto) were by then producing an array of profitable new products -- polymers, plastics, pesticides. On the other side, an alarmed citizenry demanded safety. This got translated into "safe doses."
In response to the new laws and regulations, governments at all levels geared up to make "sound judgments" inside this political pressure cooker. Under these circumstances, "risk assessment" seemed like a way to rationalize government decision-making, instead of allowing bureaucrats to make arbitrary choices: gather the necessary data, ask a group of impartial experts to interpret it, and render a sound judgment. What could be more reasonable?
Unfortunately, it did not work out. In the first place, as we shall see, the necessary data are not available, even today. In the second place, the traditional toxicological assumptions did not hold up under scrutiny. For many poisons, there is no safe dose. And finally, impartial experts are almost never impartial. Someone is paying their hefty fee and that someone often gets the benefit of the doubt when it comes time to interpret whatever data is available. Experts can be bought, it turns out.
In 1995, after risk assessment had been refined for 20 years, three well-known and well-respected risk assessors working for the California Department of Environmental Protection -- Anna Fan, Robert Howd, and Brian Davis -- published a detailed summary of the status of risk assessment.[3] In it, they pointed out:
** There is no agreement on which tests to use to determine whether someone's immune system has been damaged;
** There is no agreement on which tests should be used to assess damage to the nervous system;
** There is no agreement -- and there may never be -- on ways to test for genetic damage.
Without agreement on test methods, people cannot agree on which data to include in a risk assessment. Under these circumstances, different risk assessors will select the data that they believe is relevant and they will usually reach different conclusions -- often VASTLY different conclusions.
Furthermore Fan, Howd and Davis point out that
** Genetic damage is a non-threshold event. That is, any amount of a gene-damaging substance can cause damage. Only zero is safe. If such damage occurs in a germ cell, it may be inherited by successive generations.
** Damage to the reproductive system is a non-threshold event. Any exposure to a reproductive toxin may cause damage. Furthermore, a single exposure may have lifelong effects. The only safe dose is zero.
** Likewise, damage to the developmental system is a non-threshold event. A single exposure by an effective toxin may cause damage and such an exposure may have lifelong effects. Only zero is safe.
** Cancer is a non-threshold event. Any exposure to certain carcinogens may initiate a sequence that results in cancer. The only safe exposure is zero.
There are other problems with risk assessments:
** Science has no way to analyze the effects of multiple exposures, and almost all modern humans are routinely subjected to multiple exposures: pesticides; automobile exhaust; dioxins in meat, fish and dairy products; prescription drugs; tobacco smoke; food additives; ultraviolet sunlight passing through the earth's damaged ozone shield; and so on. Determining the cumulative effect of these insults is a scientific impossibility, so most risk assessors simply exclude these inconvenient realities. But the resulting risk assessment is bogus.
** According to the U.S. National Academy of Sciences (NAS), which in 1983 published the official formula for conducting a risk assessment,[4] risk assessments are supposed to take into account the special characteristics of the population at risk: Are they obese? Is their diet adequate? Do they suffer from chronic disorders like asthma, diabetes, or arthritis? Are they very young or very old? Are they pregnant? Do they eat unusual quantities of contaminated foods, such as cheese or fish? Most risk assessors simply ignore this NAS requirement for examining the characteristics of a population.
** Risk assessment, it is now clear, promises what it cannot deliver, and so is misleading at best and fraudulent at worst. It pretends to provide a rational assessment of "risk" or "safety" but it can do no such thing because the required data are simply not available, nor are standardized methods of interpretation. Science, as a way of knowing, has strict limits and risk assessment encompasses a set of problems too complex for science to solve. As Fan, Howd and Davis acknowledge, risk assessment is not a science, it is an art, combining data gathered by scientific methods with a large dose of judgment. Judgment is not reproducible from laboratory to laboratory so different risk assessors reach different conclusions, often based on who's paying.
** Risk assessment is inherently an undemocratic process because most people cannot understand the data, the calculations, or the basis for the risk assessor's judgment.
Now after 20 years, the public is catching on, that risk assessment has been a failure and in many cases a scam. Rather than allowing citizens to reach agreement on what's best, it has provided a patina of "scientific objectivity" that powerful corporations have used to justify continued contamination of the environment. With a few rare exceptions (sulfur dioxide emissions, for example) dangerous discharges have increased geometrically during the period when risk assessment has been the dominant mode of decision-making. It is now obvious to most people that risk assessment is a key part of the problem, not an important part of any solution.
In place of risk assessment, a new paradigm is ripening: the principle of precautionary action. The precautionary principle acknowledges that we are ignorant about many important aspects of the environment and human health. It acknowledges scientific uncertainty and guides our actions in response to it. The precautionary principle says,
"When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public, should bear the burden of proof.
"The process of applying the Precautionary Principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action."
The basic idea? Make decisions based on familiar maxims: An ounce of prevention is worth a pound of cure. Look before you leap. Better safe than sorry. Do unto others as you would have others do unto you.
This is not rocket science. Definitely not rocket science.
--Peter Montague
CLEAN PRODUCTION--PART 2
Clean production is an exciting new concept that offers environmental and economic-development activists something to be FOR instead of merely AGAINST. As we saw last week, clean production is not just about making the same old products by slightly cleaner methods; instead, it is an entirely new way of looking at materials and energy starting early in the life of a product or service, carefully thinking through each step from extraction of raw materials through manufacture, packaging, transportation, marketing, use, and final disposal. Unlike "pollution prevention" and "recycling," clean production asks fundamental questions about consumption: is a particular product even needed in the first place? And is it being produced in a way that promotes the goals of the community?
Now a loose-knit network called Clean Production Action has evolved from a two-year collaboration between environmental justice activists,[1] mainstream environmental groups, labor unions, and academics -- specifically, the Lowell Center for Sustainable Production at the University of Massachusetts at Lowell,[2] and the Center for Clean Technologies and Clean Products at the University of Tennessee in Knoxville.[3] Clean Production Action (with offices in Canada and England[4]) was created to help labor and environmental groups light a fire under governments and corporations, to promote the needed shift to the new way of thinking.
Joel Tickner at the Lowell Center says, "The purpose of the [Clean Production Action] project is to have a proactive, solutions oriented vision for the future -- the environmental movement is always on the defensive and pollution prevention isn't doing enough so we have to move beyond it. Industry and government are out there defining clean production but the grassroots movement isn't. As you know, we've always been fighting [against] things rather than saying yes to things." Clean production offers grass-roots activists something to say Yes to.
Beverley Thorpe of Clean Production Action has now written the definitive CITIZEN'S GUIDE TO CLEAN PRODUCTION,[5] which we began reviewing last week. The Guide is accompanied by a lengthy "contact list" of groups around the world working on clean production.[6] The "contact list" also includes a short but useful bibliography.
To recap, clean production has four main elements:
1) Precaution: When an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.
2) Prevention: It is cheaper and more effective to prevent environmental damage than to attempt to manage or "cure" it. Prevention requires examining the entire product life cycle from raw material extraction to ultimate disposal and choosing the least-damaging alternative (including, in some instances, the alternative of doing nothing).
3) Real democracy. Clean Production involves all those affected by industrial activities, including workers, consumers and communities. "Access to information and involvement in decision-making, coupled with power and resources, will help to ensure democratic control," says Beverley Thorpe.
4) An integrated and holistic approach: Society must adopt an integrated approach to environmental resource use and consumption. We need to think in a systems way. For each product we buy, we need to have information accessible about the materials, energy and people involved in making it. A holistic approach would avoid moving hazards around (from water to air, for example) or from the environment to workers or consumers. It would also avoid creating new problems while solving an older one (e.g., genetic engineered plants as a replacement for pesticides).
Beverley Thorpe's GUIDE offers 5 strategies that activists can use to promote clean production. Last week we discussed the first two: (1) Different ways of measuring excessive use of resources, then working to reduce the wasting of materials and energy. And (2) providing consumers with information about the full life-cycle of products and services so that they can make truly informed choices. Specifically, Thorpe urges the careful use of "life cycle assessments" -- a specific technique for studying the consequences of producing products or services.
The third basic strategy is broadly called "producer responsibility." One kind of "producer responsibility" requires corporations to publish reports on the environmental and social consequences of their business activities, and to constantly strive to improve their performance. Some corporations have begun voluntarily. For example, Hewlett Packard (HP), the electronics giant, adopted a product stewardship program in 1992. HP examines the environmental performance of its suppliers world-wide and expects them to develop (a) a policy of continuous environmental improvement and (b) a plan for implementing the policy. For example, HP's suppliers are expected to find the least-damaging and most-reusable plastic resins.
Some retailers have begun to take responsibility for the products they sell. For example, the Swedish retailer of home furnishings, IKEA, refuses to sell products made by unsustainable forestry practices or made from PVC plastic. B&Q, a major do-it-yourself housewares and sporting goods chain in Britain, ensures that all of its products are certifiable as having been produced by sustainable forestry practices. By the end of 1999, B&Q suppliers will be expected to know the key impacts of each of their products, throughout the product's life, and have a specific program to reduce those impacts. For example, all of B&Q's carpet suppliers are required to get involved in efforts to produce recyclable carpeting, and suppliers of bathroom products are required to seek alternatives to PVC plastic.
Products have social impacts as well as environmental, and the Clean Production Network considers both kinds equally important. For example, the CITIZEN'S GUIDE TO CLEAN PRODUCTION describes the international Clean Clothes Campaign,[7] which is an alliance of retailers, consumer groups, and national solidarity groups in India, the Philippines, and Bangladesh, plus labor unions, women's organizations, and churches. The Clean Clothes Campaign holds retailers and clothing companies accountable for poor working conditions in the garment trade, as well as the intensive use of pesticides to grow cotton. The Campaign has negotiated a code of conduct for retailers and buyers called the Fair Trade Charter for Garments.[7]
Thorpe highlights other examples: the Clean Computer Campaign developed by the Silicon Valley Toxics Coalition in San Jose, California, for example, which is producing a "report card" on each computer manufacturer and is advocating that manufacturers "take back" their computers for reuse and recycling when they become obsolete.
Thorpe's GUIDE offers a useful list of questions that can be asked of any manufacturer, retailer, restaurant, or even school cafeteria manager regarding their efforts to locate and purchase minimally damaging goods.
Thorpe's point is that "free trade" is making government regulations less and less effective as time passes, but corporations can still be pressured by organized citizens. As Thorpe points out, the success of the anti-genetically-engineered food campaign in Europe has shown the power of consumers.
Another approach is to establish alternative consumption patterns directly, not waiting for corporations to reform their behavior. For example, community supported agriculture (CSA) offers a way for communities to support family farms, provide themselves with wholesome, reasonably-priced food and at the same time withhold their support from agrichemical corporations and the chemicalized farms they hold in thrall.[8]
A new idea, now spreading throughout Europe and parts of Asia, is called "extended producer responsibility" (EPR). It basically means that the manufacturer retains responsibility -- physical responsibility, economic responsibility, and legal liability -- for a product throughout the product's life. In the extreme case, the consumer never owns the product at all, but leases it from the manufacturer who is obligated to take it back when its useful life is over. EPR initiatives are being worked out now in Austria, Germany, Belgium, France, the Netherlands, Sweden, Japan, Taiwan, Korea and the UK. Clearly, this is an idea whose time has come. However, Beverley Thorpe reports that the U.S. government is lobbying hard to kill EPR initiatives, on the grounds that such laws represent barriers to free trade. The U.S. government also argues that everyone bears responsibility for the products that manufacturers offer us and that it is therefore unfair to hold manufacturers responsible for their actions.
In her "what you can do" section, Thorpe recommends that activists get their local government to initiate a "green" procurement policy, refusing to purchase toxic materials, for example. Or join the campaign, spearheaded by the Silicon Valley Toxics Coalition, to support EPR initiatives.[9] Or replace your local recycling campaign with a local Extended Producer Responsibility Campaign. As Thorpe's GUIDE points out, "We should recycle, but it is not the first thing we should do; it is the last. Redesign first, then reduce, reuse and finally recycle if there is no other alternative."
Two other strategies for moving toward clean production are ecological tax reform and ending government subsidies for polluting industries.
Ecological tax reform aims to shift taxes away from value-adding activities (such as work) and onto value-depleting activities, such as water pollution and logging old-growth forests. As a soon-to-be-released report from Sustainable America says, instead of taxing wages and income, we could be taxing carbon (i.e., fossil fuel use); major pollution sources; fertilizers and pesticides; vehicle emissions; land speculation; contaminated sites; waste; water; and the depletion of forests and fisheries.[10] Environmental taxes are usually intended to be "revenue neutral" -- they don't cost any more than present taxes, but they provide new incentives for preserving neighborhoods, waterways, and other natural resources.
Ending government subsidies to polluting corporations is an obvious way to promote clean production -- a subject we will cover in a future issue, though not next week.
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