Initiation

Preliminary Analysis

Risk Estimation

Risk Evaluation

Risk Control Risk Communication

Action/ Monitoring

Risk Management Framework: Step 4

RISK EVALUATION The Risk Evaluation step examines the economic and social issues influencing the selection of control options intended to ensure acceptable levels of risk. These considerations deal extensively with individual and societal values, and thus they go far beyond the scientific notion of objective analysis of ‘empirical’ (measurable) physical quantities. Instead, risk evaluation techniques focus on the exploration of ‘normative’ issues related to what ‘ought to happen’ in a society that seeks to provide effective protection of the health its citizens in an equitable, but affordable, manner.

Most of us will rely to some limited extent on governmental or private-sector organizations to assist us in controlling the major sources of risk—violent crime, fraudulent financial dealings, incompetent medical treatment, and similar uncontrollable hazards. But otherwise we expect to manage a large portion of our personal risks by the independent personal decisions we take as informed, responsible adults. In contrast, environment risks are often seen as different than the other common risks we encounter in modern society. We tend to value our personal and family health above all other goods. But when undetectable environmental hazards such as toxic chemicals, radioactive substances, and pathogenic organisms invade our immediate environment, most of us feel powerless as individuals to control or manage these risks.

Because it is so difficult for us as individuals to effectively control personal exposure to environmental contaminants, we collectively depend to a great extent on societal safeguards. These may be either government environmental regulations that have the force of law, or

private-sector guidelines that require voluntary adherence by corporate members of business organizations.

However, the complexities of dealing with environmental health risks means that scientific risk estimates have little intuitive meaning to non-experts like ourselves, in part because we tend to focus on the severity of consequences for a given risk rather than the numerical probability of its occurrence. We often evaluate risks according to our subjective perception of the threatening characteristics of a particular hazard that most stand out in our minds as memorable and menacing. In order to compensate for such distortions in public perception of risk, decision-makers and stakeholders must rely, in part, on a systematic review of the economic and social dimensions of risk to provide a more pragmatic approach to the identification and selection of effective risk reduction strategies.

Two major classes of normative societal issues are considered in the Risk Evaluation step:

Economic evaluation—estimating the expected health benefits and anticipated costs of control associated with varying degrees of reduction in risk, using monetary criteria which are amenable to quantitative economic analysis

Social evaluation—characterizing the social issues that reflect value judgments and societal preferences which are not amenable to formal economic analysis, as well as the factors that influence political perceptions of equity and fairness.

Economic Evaluation

Economic evaluation considers the projected costs of implementing an environmental improvement program, together with the corresponding benefits of expected future improvements in population health. This approach provides risk managers with the ability to evaluate and select the best available environmental control strategy from a range of proposed options. As the term suggests, economic evaluation involves the assigning of subjective values, usually expressed as money values, to quantify health benefits gained from the reduced incidence of disease (morbidity) and lessened risk of premature death (mortality).

0RQHWL]DWLRQ RI +HDOWK 5LVNV Risk assessors are responsible for providing quantitative estimates of the projected amount of health risk incurred from an existing contaminant exposure, as well as the degree of risk reduction that might be anticipated from various levels of reduced exposure. Health economists must then convert any projected decreases in population morbidity and mortality into monetary values expressed in dollar terms. This technique is termed the monetization of risk, and it involves

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 putting a ‘price tag’ on various harmful outcomes to human health. For example, the ‘cost of a life’ that is terminated by premature mortality might be assigned a dollar value according to incurred costs. These costs are based on economic estimates of diminished future income, such as the lost wages for an ‘average’ wage earner of a specified age, or on the amount of damages typically assigned by the courts in lawsuits related to premature death. Similar methods can be used for monetizing the subjective value of avoiding a brief illness or a chronic illness not related to premature mortality.

One of the most common methods for monetizing a life lost (or saved) is called contingent valuation. Polling organizations periodically survey large numbers of people across the country by administering a series of questions to determine how much the respondents feel an increase in their life expectancy (e.g. 6 months) due to reduced risk of ill health would be worth to them in dollar terms. The ‘cost of a life’ can then be then calculated by scaling up the dollar values for the smaller gains of life expectancy to encompass the entire life expectancy (70–80 years) of a person. In Canada and the United States, the average dollar value for a life lost, estimated by the ‘willingness to pay’ method of the contingent valuation, spans a range of monetary values from about 1.5 to 4 million dollars. The actual value depends on the phrasing of the survey questions and the characteristics of the population sample (it is unclear whether the life of Canadians is less valuable than the life of Americans, given the lower exchange value of the Canadian dollar). Similar valuation methods can be used for valuing various morbidity outcomes, from mild illnesses lasting a few days, to severe illnesses that are chronic and sometimes incapacitating.

The practice of monetizing health risks through life valuation methods is frequently criticized as fundamentally immoral—trading off people’s lives versus money. In fact, its primary purpose is to allow the estimated costs and anticipated health benefits of a control strategy to be directly compared using ‘commensurable’ quantities expressed in the same units of measurement. After projected costs and benefits have been quantified in dollar terms, the ultimate decision to introduce more stringent environmental controls is a subject for risk decision-making. Economic evaluation can inform the decision process for risk managers, but it does not compel decision-makers to adopt a particular course of action

It is also important to note that monetization of life or health is based on the projected statistical probabilities of disease or death, as defined by the risk estimates and the assigned monetary values for particular health outcomes. Given that most risk estimates and monetized health effects contain several conservative assumptions, a typical economic evaluation will usually represent the hypothetical worst-case scenario for a potential harmful outcome. Actual health consequences are likely to be considerably smaller than those predicted in the formal economic

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 analysis, and they may in fact be as small as zero. Therefore, what is being monetized is the ‘statistical value of a life’ according to mathematical projections, not actual human lives being placed in obvious peril. Virtually all stakeholder groups, including most The economic analysis may be government regulators and business organizations, consistently assert misleading if the value assumptions that they would never intentionally sacrifice a human life or impair included within the economic model human health under circumstances where harm to people is a clear and are biased or unrealistic. For present danger. example, if the cost-of-a life is valued at, say, four million dollars, does this mean that all lives are to be valued at In practice, there is greater concern among many economists about the this level? In theory, many people general over-estimation of expected health benefits, given the inflated would answer in the affirmative. But estimates of health risks predicted by conventional risk assessment what about toxic air contaminants methods. It is therefore essential that risk estimates and their associated that shorten life by only a few days or uncertainties, underlying exposure assumptions, and monetized dollar weeks, for example, by causing respiratory failure or heart failure in values assigned to various morbidity and mortality outcomes should all elderly people with advanced lung be explicitly stated and clearly explained whenever an economic diseases, such as emphysema? analysis of risk reduction strategies is presented. Similarly, a detailed Clearly their lives are worth description of the predictive economic model, which economists use to something, but how do we monetize compute projected costs and benefits, must be made fully accessible to the value of a life that is almost over? public scrutiny, so that any potential weaknesses and underlying assumptions can be made more transparent. Otherwise, the projected cost and benefits in the economic evaluation are merely the product of a ‘black box’ computer program, whose predictions are questionable and interpretations unverifiable.

(RQRPL $QDO\VLV 0HWKRGV Several different types of economic analysis techniques can be used at the risk evaluation step. Among the methods most commonly used are the following analytical techniques:

1. Cost-Effectiveness Analysis

2. Benefit-Cost Analysis

3. Risk-Benefit Analysis

4. Socio-Economic Impact Analysis

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The most straightforward of the economic analysis approaches is termed cost-effectiveness analysis, a method which compares the relative projected costs for a range of proposed risk control options, all intended to meet the same objective. At the beginning of a cost- effectiveness analysis, risk managers must first provide a clear specification of the principal objective for the desired level of risk reduction. There are at least two means of selecting the risk reduction objective—by relying on risk assessment methods to define an appropriate exposure limit using standardized criteria (e.g. a de minimis

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 risk level), or by achieving a consensus among stakeholders with respect to a proposed exposure limit.

Once a clear objective is determined, a number of different control options can be identified and developed in detail. Although all options are designed to meet the same objective, they may adopt widely different means to reach this end. The number of possible options depends on the nature of the particular problem, but three to five different strategies are examined in a typical cost-effectiveness analysis. The cost-effectiveness analysis aims to identify the most economic means of achieving the desired control objective. The projected costs of the various control options are relatively easily to estimate, as there is no need to quantify the benefits of improved health or safety.

It is essential that all options are capable of providing equally effective levels of environmental protection, to permit the options to be compared on an equal footing within the analysis. Each analysis will typically calculate all projected costs according to a method called the method of present value. The present value method transforms future cash expenditures (or reduced income flows) over the life of an investment into their present monetary equivalents. Therefore the costing of different control options can be compared on an equal basis, taking into account the dependence of costs on the period of time required for implementation. The most cost-effective option is the one that can be implemented at the lowest present value cost.

The merits of the cost-effective analysis method are that its calculations are straightforward and it can identify the least expensive control option out of a range of possible options with a minimum amount of information. To work successfully, risk managers must develop an assortment of realistic control options to allow the risk evaluation to compare meaningful alternatives, and the control objective must remain acceptable to the stakeholders after the analysis is completed. Under these conditions, the cost-effective analysis will be able to identify the least expensive option available to the affected stakeholders.

The disadvantage of the technique is that it is often overly restrictive in its scope. The declared objective at the beginning of the analysis is not always seen as desirable once a study is completed. In addition, the quality of the different control options is graded solely by cost. Usually there are other non-economic factors to be considered in an environmental health decision that cannot be graded exclusively by cost. For example, the most cost-effective control strategy for a contaminated soil site might include reducing the exposure by fencing off the area to local residents. However, the economic analysis cannot estimate the impact of negative publicity on the site owners if local residents were to demonstrate in front of the site and receive media attention. The cost-effective analysis cannot take into account social

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 and political factors unless a monetary value can somehow be placed on them.

It is the responsibility of the risk manager to carefully review the economic analysis to gauge the importance of non-economic factors with respect to cost-effectiveness. The technique is generally seen as capable of providing useful information to decision-makers, but it should not be used as the sole criterion for selecting and implementing a control strategy. The technique is commonly employed in many business organizations to help resolve environmental control problems, such as selecting the location for a corporate hazardous material site or for planning a system for the removal of industrial wastes. The method often proves amenable to the planning needs of private-sector organizations, as it is consistent with the finite financial resources under which most businesses operate, and can be readily evaluated Benefit-cost analysis is a standard according to a company’s immediate priorities and long-term budgeting technique that has been objectives. adopted by the Treasury Board of Canada as means to achieve the most Another difficulty with cost-effectiveness analysis is that its success efficient allocation of governmental and societal resources. It is intended will depend on the feasibility of the options initially selected for to provide guidance to all federal evaluation. The best control method cannot be considered if it has not government agencies regarding the been included in the range of options initially under analysis. measures and methods to be followed Sometimes the ideal control solution is a combination of two or more when conducting a benefit-cost distinct control options—for example, a contaminated site might best analysis for regulatory decision- making in the federal government. be managed by combining two different remedial actions, such as The last update of the Treasury removing the most heavily contaminated soils and reducing exposure to Board’s Benefit-Cost Analysis Guide the location by capping with asphalt. If the scope of the analysis is was issued in 1995. defined in too narrow a fashion, the ideal solution to a problem will likely remain unexplored. Cost-effective analysis is the economic An important feature of benefit-cost analysis is that it only deals with the evaluation technique most likely to be subject to these types of allocative effects of a control option. constraints. The allocative effects are restricted to those costs and benefits that can be %HQHILW&RVW
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measured solely as direct consumption and production. The The benefit-cost analysis approach (also termed cost-benefit analysis or analysis does not regard the impact risk-cost-benefit analysis) compares the estimated costs of improved of a control strategy on larger issues environmental controls against the expected benefits of the reduced such as inflation rate, trade balance, likelihood of illness associated with various exposure reduction industrial competitiveness and productivity, or employment. The scenarios. When the monetized benefit-cost ratio is found to exceed scope is wider than the cost- one, this indicates that the projected health benefits will likely outweigh effectiveness analysis because the the costs of control. Thus, we would normally conclude that an future health benefits are measured environmental control program appears to make good economic sense against control costs. However, the when the expected benefits outweigh the costs. Conversely, a benefit- analysis is not as extensive as that used in a formal socio-economic cost ratio less than one would suggest that an environmental strategy is analysis, and so the analyst is not defensible in strictly economic terms, although this does not relieved of the duty to calculate non- necessarily disqualify it from further consideration on non-economic allocative effects. grounds.

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 Reflecting the degree of subjectivity and uncertainty that exists in most environmental economic analyses, benefit-cost analysis is generally an unreliable predictor of absolute economic efficiency, but it is much better suited for exploring relative economic efficiency for a series of alternative risk reduction options. For a specified set of proposed control options, the projected benefit-cost ratio for each of the options under consideration will contain a wide array of underlying measurement uncertainties and subjective assumptions. These sources of error will introduce bias, and therefore a given benefit-cost analysis will frequently produce inaccurate predictions of absolute efficiency. However, such errors, if they are common to all options, will result in an equal amount of bias for all the computed benefit-cost ratios across a series of options. Therefore, comparing and ranking the benefit-cost ratios for alternative control options is a more reliable and informative approach to economic analysis than considering each ratio by itself. The main necessary condition here is that all of the benefit-cost calculations must be performed using identical monetized values and computational assumptions.

Some risk managers might conclude, incorrectly, that any control measure whose calculated benefit-risk ratio is less than one is a One common fallacy of benefit-cost fundamentally infeasible strategy, which should be rejected out of analysis is the assumption that precautionary actions should only be hand. However, accepting any single benefit-cost ratio at face value, as initiated when there is a positive the absolute indicator of economic feasibility of an environmental benefit-cost ratio, that is, when the program, can be highly misleading. Instead, risk mangers should select benefits of new controls clearly a control strategy which demonstrates the highest benefit-cost ratio outweigh their costs. In fact, relative to several other alternative control options. The absolute value considering the uncertainties and subjective values inherent in the should be considered only as an approximate indicator of whether the deriving a benefit-cost ratio, any proposed option is desirable or undesirable in light of other decision finding that the relative costs and criteria, such as social and legal concerns. benefits approximate each other should be deemed sufficient to If the benefit-cost ratio for a control option is high, for example 10 or consider further the various controls options that the stakeholders have at more, then its positive economic efficiency is not a contentious issue. hand. The size and direction of the Likewise, if the benefit cost ratio is very low, perhaps 0.1 or less, it is benefit-cost ratio should be treated as likely that the control option will not be treated as a viable option. one important factor in the risk However, when a control option has a calculated benefit-cost ratio management decision-making slightly less than one, say, 0.8, there may nonetheless be good reasons process, but it should not constitute an overriding factor that can be used to consider retaining this option as a viable strategy, unless another as an excuse to terminate decision- equally effective control measure were identified that had a superior making prematurely. benefit-cost ratio. For many existing environmental health programs, the calculated benefit-cost ratio is often found to be somewhat below the ‘break-even’ point, where the ratio is less than one. Such programs may nonetheless represent politically justifiable activities if there is a concerted public demand for substantial improvements in environmental protection.

The greatest difficulty with the benefit-cost analysis approach lies with the monetization of projected health benefits. The use of monetized values for weighing costs and benefits sometimes makes this type of

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 analysis difficult, or even unsuitable, for use in a risk evaluation. In theory, the money value of an illness avoided can be determined using output accounting, where the costs of medical treatment are measured together with the estimated loss of family income from an illness, and perhaps the associated personal discomfort and disability. A second Many business organizations object method uses welfare economics as the basis of calculating health to the compounded conservatism that benefits. Under this method, the public’s ‘willingness to pay’ for frequently creeps into the benefit-cost analysis for environmental improvements in particular health protection programs, expressed in regulations. To the extent that a dollars, is determined by surveys and interviews. A reliable single quantitative expression of risk determination of the cost of an illness, if there is one, is the major is provided by the risk assessors, this stumbling block to the utilization of this type of analysis. risk estimate may often include an inherent bias towards worst-case scenario assumptions. Another difficulty with benefit-cost analysis is that its success depends on the correct identification of suitable control options prior to the Instead of selecting the best-fit analysis. If the risk control options are poorly conceived, without estimate of risk, economists are often adequate accounting for best technology or best practice, then it is guilty of adopting without question inevitable that many of the options will have relatively poor benefit- the 95% upper-bound risk, which suggests a much higher level of cost ratios, and all might then be rejected as infeasible. Thus, it is projected risk. The monetized benefits crucial that knowledgeable stakeholders make a major contribution to of risk reduction are then overstated, the development of control strategies and the estimation of costs which inflates the calculated benefit- associated with those options. The relevant stakeholders in the business cost ratio. To avoid this pitfall, it is sector will often have technical and cost information not otherwise necessary include several statistical measures of risk—best-fit risk, lower- available to the government decision-makers, which is extremely useful bound risk, upper-bound risk—and for identifying the most efficient control initiatives. However, much of then perform a sensitivity analysis the private sector information about control technology effectiveness using each of these values in turn, to and costs is typically treated as proprietary information by competing determine what effect the uncertain companies, constituting a portion of their ‘intellectual property’, which risk estimates will have on the final benefit-cost ratio. cannot be revealed to competitors. A confidential liaison between companies that own useful private information and the government agencies that need this information should be encouraged, through the stakeholder consultation process.

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Frequently the cost function is not a smooth line, but instead will jump in A risk-benefit analysis operates by the same basic principles as benefit- magnitude as a different type of cost analysis, except that the measure of health benefits is calculated as control technology is introduced to a reduction in estimated health risk, and is not converted to a monetary further reduce exposures. The unit. In other words, the monetization of health risk is not attempted. selection of the most suitable control option is dependent on the level of This approach retains the same advantages of sound analytical appraisal risk and cost decided upon. characteristic of the benefit-cost analysis. However the calculation of human risk remains distinct within the economic analysis. For example, the reduction of volatile organic carbons (VOCs) emitted to Most risk-benefit analyses attempt to define the relation between a the air has long been a regulatory concern. Initial control methods given amount of risk reduction and the cost of environmental control were able to reap significant measures necessary to achieve it. An incremental reduction in the reductions with relatively low costs. degree of health risk will require some corresponding incremental rise However, to implement reductions in the cost of control. Usually the risk-benefit relationship does not using current regulations requires a follow a one-to-one linear relationship across its entire range. The cost substantial expense for only a small or moderate change in emitted levels. of control for an initial reduction of health risk at high levels of

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 exposure will be relatively inexpensive compared to a further reductions in the remaining amount of risk at incurred at lower levels of exposure. Economists term this type of non-linear risk-benefit relationship ‘the law of diminishing returns’.

It is assumed that the risk estimation calculations can provide the economic analyst with a range of predicted risk numbers for a given range of contaminant exposures. The risk manager must then examine the economic costs of implementing possible control options to limit exposure in the environment. Preferably, a variety of control options will provide the analyst with a suitable range of exposures from which to choose. The predicted costs of various control options designed to reduce exposure to pre-specified lower levels can then be compared to the residual health risks associated with the lowered exposure levels.

When attempting to control high-risk environmental contaminants in a formal regulatory setting, a risk-benefit analysis is frequently the most credible risk management technique. It is wider in scope than the limited cost-effectiveness analysis. In addition, risk-benefit analysis allows risk managers to define an ‘acceptable’ level of risk without The Canadian federal government first initiated the use of SEIA’s as a requiring the conversion of human health benefits into monetary Treasury Board Policy in August of measures. Instead, the relationship between a level of control and an 1978. The policy required all federal acceptable level of risk is estimated directly. A risk-benefit analysis is departments and agencies to consult the method of choice for many risk control evaluations. However its with affected parties when usefulness is dependent on the prior determination by stakeholders of considering new regulations. In addition, the federal body was an ‘acceptable’ level of risk. required to publish the results of the SEIA for public comment prior to 6RLR(RQRPL
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promulgation of the regulations. The policy only applied to new or The most comprehensive and most complex risk evaluation method is amended regulations in the areas of termed socio-economic impact analysis (SEIA). While there is virtually health, safety, and fairness. no limit on the allowable scope that an SEIA may adopt, its application in risk evaluation is usually restricted to evaluating the impact of major Since its inception, the policy has new regulatory initiatives proposed by a government agency. It is not made considerable progress in rendering the regulatory process considered necessary to conduct a full socio-economic impact analysis more responsive and accountable to every time there is a proposed change in existing government the needs of the country. On several regulatory standards. occasions, the calculation of allocative effects, in particular, has An SEIA contains all the elements of a formal benefit-cost analysis in allowed substantial savings in the costs of regulatory controls to be determining allocative effects, that is, those effects concerning direct realized. In the near future, the SEIA production and consumption. However, the SEIA method goes far may serve an appropriate evaluation beyond the benefit-cost analysis by examining an array of tool in assessing the Canada’s non-allocative effects as well. Non-allocative effects may include the commitment to the Kyoto Agreement anticipated impacts of proposed new government regulations on a on greenhouse gas emissions. This commitment will produce profound number of economic and business issues: industrial and societal impacts by changing the future economic • the distribution of income valuation of petroleum products as (between individuals and between regions) energy sources in relation to other energy sources. • technological progress

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 • market structure and competition

• employment

• international trade

• balance of payments

• inflation rate

Non-allocative effects, by their very nature, are difficult to characterize and will include many uncertainties. Nonetheless, these types of issues merit serious consideration whenever an envisaged regulation is thought to have potential impacts large enough to materially affect some significant segment of national or provincial economies.

Social Evaluation

The notion of acceptable risk concerning environmental hazards is a subjective value that is strongly influenced by societal norms and There are serious difficulties in expectations about safety. Safety therefore does not denote the absence attempting to view risk as a one of risk, but rather the acceptability of risk under certain conditions dimensional objective concept. In particular, risk perception cannot be defined by social influences. Acceptable risk is determined less by the reduced to a single correlate of a objective level of risk than by the subjective risk tolerance of the particular mathematical aspect of exposed individual. There is an old saying in environmental risk risk, such as the probabilities and management that “Perception is reality.” Despite the best efforts of consequences of an event. Risk scientists and economists to explain and defend the risk estimates and perception is essentially multidimensional and personalistic, cost-benefit ratios that they have calculated, public acceptance of risk with a particular risk or hazard continues to be greatly influenced by factors unrelated to science or meaning different things to different economics. Many of these factors are social factors, which include the people and different things in following: different contexts. Given the essentially conditional nature of all risk assessments, one should accept • risk perception that assessments of risk are derived from social and institutional • anthropogenic hazard assumptions and processes; that is, risk is socially constructed. • comparative risk Royal Society Study Group (U.K.), • risk equity 1993; as quoted in Illing, 1999.

5LVN 3HUHSWLRQ Environmental health risks present themselves with three important risk perception factors that make them inherently difficult to manage on a societal basis. unknowable

As members of a technologically advanced industrial society, many of us feel we are faced with constant exposure to a ‘chemical soup’ of

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± several thousand potentially toxic pollutants whose hazardous properties are typically unfamiliar to us and whose possible consequences are obscure but frightening. We also possess little personal information about the levels of exposure we incur for many hazardous pollutants, and whether such exposures are likely to imperil our health. Environmental health risks are therefore often viewed as unknowable at a scientific/technical level, and accordingly the public tends to treated them in a black-and-white manner—either with unconditional acceptance (or indifference), or with absolute intolerance for any level of exposure. involuntary

As we encounter most environmental pollutants in trace amounts below our sensory thresholds of taste and smell, our exposure to hazardous agents is largely unavoidable by personal precautionary actions. Moreover, we cannot isolate ourselves from contact with the natural environment—the air we breathe, the water we drink, the soil we walk on, and the food we consume. Environmental health risks appear to be imposed upon us by faceless industrial corporations and anonymous government bureaucracies. We feel that these risks are involuntary, and therefore largely unacceptable. unbeneficial

When we are exposed to environmental pollutants, they apparently obtain no visible direct benefit to us, either as increased personal wealth or reduced disease burden. There is presumably a net societal benefit that everyone shares from the productive economic activities of Canadian industries—employment income, investment income, government revenue, and myriads of valuable consumer and health products—but the flow of rewards and the imposition of risks appear to be allocated to different groups of people in a unequal and unfair manner. In contrast, while the pharmaceutical drugs we take will often exhibit toxic side-effects potentially harmful to health, we feel these risks are usually outweighed by the therapeutic benefits of the drugs in the treatment of disease. Environmental health risks are commonly deemed unbeneficial, because we feel that we can subjectively sense our personal health risks, but cannot adequately evaluate our collective economic benefits.

$QWKURSRJHQL +D]DUG Since many environmental pollutants are generated both by human activities and natural processes, the distinction between synthetic and natural contaminants is confusing and misleading. The preferred terminology distinguishes between natural sources of hazards in the environment and anthropogenic sources attributable to human activity. The proper distinction then can be made with respect to the source of

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± production and the relative contribution of natural sources and anthropogenic sources.

This distinction says nothing about inherent toxicity, but does allow consideration of the relative burden that anthropogenic sources make with respect to overall pollution levels. Risk managers do not weigh anthropogenic burdens more heavily because they dislike them more, but because they recognize that human polluting activities are usually more amenable to control and remediation than are many natural pollution sources.

5LVN 7ROHUDQH Risk tolerance examines differences in the allowable risks for a given substance in one regulatory jurisdiction, in contrast to risk benchmarks in other regulatory jurisdictions. Several concerns must be addressed by risk managers—consistency, relevance, and impact. consistency

Regulated substances that are present in several environmental media are often regulated independently by separate groups of risk managers. Even within the same organization, the consistency of exposure limits for a given chemical in various media is often lacking, because different risk assessment methods have been employed, or because different economic and social criteria have influenced the development of exposure standards which permit divergent levels of residual risk. Consistency between different regulatory bodies and standard-setting organizations regarding risk estimates and exposure estimates is especially important with the advent of free-trade policies, because ‘harmonization’ of regulatory standards seeks to eliminate divergence between environmental exposure limits across regional and national boundaries. relevance

Risk estimates should not be allowed to stand on their own without comparison to other risk estimates. Exposure limits can only be meaningful if they are able to reduce health risk in the face of competing risks from the natural environmental or from other human activities. For example, it makes little sense to try to control water pollution from chemical herbicides exclusively through tighter restrictions on agriculture and industry, if application of herbicides for residential, civic, and recreational uses is left relatively unchecked. impact

The expected impact of various risk reduction options would normally be evaluated according to the following criteria—the severity and

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± irreversibility of disease outcome, special groups to be protected at more stringent levels of risk (e.g. infants and children for neurological hazards), and changes to existing body burden in previously exposed groups (e.g. native groups consuming game and other ‘country food’).

5LVN (TXLW\ Consideration of risk equity and environmental justice in the control of hazardous contaminants is becoming an increasingly important issue in risk evaluation. The unequal distribution of economic benefits and the burden of health risks must be carefully examined especially when vulnerable subgroups or disadvantaged minority groups are disproportionately exposed. These concerns frequently become translated into the political arena as a question of fairness.

When, as potentially affected individuals, we view the distribution of risks and benefits as inequitable, our natural response is anger and distrust. This often leads to a political reaction called ‘NIMBY — NOT IN MY BACKYARD.’ The NIMBY syndrome is more closely related to the social issues of concerned citizens, such as equity and risk perception, than to arguments over scientific evidence and risk assessment methods. This type of concern is best addressed by effective stakeholder participation, including ongoing consultation with citizen’s groups and environmental advocacy organizations. Such problems can be effectively addressed by careful consideration of risk equity issues, as one aspect of the Risk Communication process

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± SUGGESTED READINGS

Alhakami, A.S., Slovic, P. (1994). A psychological study of the inverse relationship between perceived risk and perceived benefit. Risk Anal 14:1085-96.

Barnard, R.C. (1990). Some regulatory definitions of risk: interaction of scientific and legal principles. Regul Toxicol Pharmacol 11:201-11.

Barnard, R.C. (1991). Major issues raised by the OMB report from the perspective of the regulatory agencies. Regul Toxicol Pharmacol 14:223-8.

Barnard, R.C. (1996). Executive Order 12866: Advantages and disadvantages of the administration’s new regulatory plan on risk, benefit, and costs. Regul Toxicol Pharmacol 23:178-82.

Barnard, R.C. (1996). A new approach to risk assessment integrating scientific evaluation and economic assessment of costs and benefits. Regul Toxicol Pharmacol 24:121-5.

Brunk, C., Haworth, L., Lee, B. (1991). Value Assumptions in Risk Assessment: A Case Study of the Alachlor Controversy. Waterloo, Ontario: Wilfrid Laurier University Press.

Canadian Standards Association (1997). CAN/CSA-Q850-97. Risk Management: Guideline for Decision-Makers. Etobicoke (Toronto), Canada: Canadian Standards Association.

Cap, A.P. (1996). The chlorine controversy. Int Arch Occup Environ Health 68:455-8.

Cothern, C.R., (Ed.) (1996). Handbook for Environmental Risk Decision Making: Values, Perceptions, & Ethics. CRC Press.

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Fischhoff, B., Bostrom, A., Quadrel, M. (1993). Risk Perception and Communication. Annu. Rev. Public Health 14:183-203.

Flynn, J., Slovic, P., Mertz, C.K. (1994). Gender, race, and perception of environmental health risks. Risk Anal 14:1101-8.

Frank, J.W., Newman, J. (1993). Breast-feeding in a polluted world: uncertain risks, clear benefits. CMAJ - Canadian Medical Association Journal 149:33-7.

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± Hattis, D., Anderson, E.L. (1999). What should be the implications of uncertainty, variability, and inherent “biases”/“conservatism” for risk management decision-making? Risk Anal 19:95-107.

Illing, H.P. (1999). Are societal judgments being incorporated into the uncertainty factors used in toxicological risk assessment? Regul Toxicol Pharmacol 29:300-8.

Joint Committee on Health and Safety, Royal Society of Canada, Canadian Academy of Engineering (1993). Health and Safety Policies: Guiding Principles for Risk Management. Waterloo, ON: Institute for Risk Research.

Kamrin, M.A. (1997). Environmental risk harmonization: Federal/state approaches to risk assessment and management. Regul Toxicol Pharmacol 25:158-65.

Kopp, R., Krupnick, A., Toman, M. (1997). Cost-Benefit Analysis and Regulatory Reform: An Assessment of the Science and the Art. Washington, DC: Resources for the Future (RFF).

Krewski, D., Slovic, P., Barlett, S., Flynn, J., Mertz, C.K. (1995). Health risk perception in Canada I: Rating hazards, sources of information, and responsibility for health protection. Human and Ecological Risk Assessment 1:117-132.

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