Acceptable Risk
by Adam J. Smargon


Risk assessment is a controversial topic in the world of environmental legislation. Much of it deals with science (and how assessments depend on it), and the judgement calls dressed up as "acceptable risk." Both issues shall be addressed in this heated debate over risk assessment.

My personal definition of "risk assessment" is that level of risk that a regulatory agency feels comfortable taking when the safety and goodwill of the people are at stake. That, in and of itself, is the key dilemma. All definitions of "acceptable risk" are truly personal -- they vary in some degree from person to person. There are legal definitions of acceptable risk, which one might hope to be rigid and inflexible to avoid controversy, but they are not. They are intentionally written vaguely, which invites controversy (which should lead to an inevitable compromise).

The legal determination involves four criteria. Margin-of-safety criteria deals primarily with a standard of protection, plus an additional margin of safety. Cost-sensitive criteria and cost/benefit criteria are determined by the governmental agency, who consider the cost of regulation with the benefits of setting the standards. Also, cost/benefit criteria is used with health-related criteria in regards to unreasonable adverse effects on human health or the environment.

But ultimately, somewhere in the process, someone down the line is forced by policy or circumstance to translate their opinion to an official decision that will affect the lives of at least some of the people of this nation. This is not meant to sound so grandiose in philosophy, but who's to say? Who really should have the right to decide what levels are generically safe for specific chemicals? In reality, it is somewhat like playing God -- unknowingly allowing some to live and some to die. Those that die will do so because their own bodies could not tolerate the allowed level of whatever chemical was decided upon by some middle-management suit in some Washington bureaucracy. It's kinda scary. Personally, I don't think I'd want that kind of vague power.

"Acceptable risk" is also important politically as well -- it is highly sensitive to politics and ideological biases. While in office, President James Carter desired a high level of enforcement for a chemical -- a level at the high end of tolerance -- in his liberal, active-government administration. But when he lost to Ronald Reagan in 1980, the new president ordered that that tolerance be lowered. He was not necessarily cruel or unfeeling towards those with lower tolerances, but that he wanted a relatively safe level. He did not want one with such a high price tag as Carter decided. Reagan, who wanted a less powerful federal government, wanted to save taxpayers the money. This was a benefit (taxes paid to the federal government) which outweighed the cost (any marginal disease or death to humans or harm to nature).

In the actual process of risk assessment, the scientific tests and conclusions should theoretically be separated from the policy-oriented analyses and actions. In practice, however, they can be -- and are -- linked. Science is a remarkably crucial point of environmental policymaking -- it is required as a contributor in studies as the basis of information for constructing policy. However, scientists cannot always guarantee that the data will be on time, complete, accurate, or even present at all when desired. It may not be in the right format, or even the kind of data required by the policymakers. Science can also influence their own beliefs -- even political ones -- into the data. When data is not perfect, it can promote confusion in the process to define acceptable risk.

There are many other factors which raise controversial questions about risk assessment. Enormous discretion is given to agencies on how to balance the criteria for assessing risk. The quantity and complexity of the criteria forces agencies to spend time, money and energy to decipher them into workable processes. Questions are raised which can only be answered by opinions. Time is an enemy of the environmental policymaker, because s/he wants to show the people what s/he has done for them, but environmental data is collected at a remarkably slow pace -- usually measured in years. In politics, this is a lifetime. Furthermore, it is difficult to separate scientific fact from non-scientific statements (such as conclusions, or opinions, which again brings up the controversial issue of acceptable risk). Conflicts of interest and opinion refute each other in the process of defining acceptable risk.

In the world of assessing risk, it is a strange and sobering thought that somebody in Washington is deciding on levels of tolerance of chemicals which may play a part in the drama that is the lives of the lives of this nation. The world of science has a supporting role in this fate. It can be frightening, but as the government has sworn, it must protect the people from harm.


Copyright © 1994-99 Adam Joshua Smargon --- recycler@afn.org
Acceptable Risk --- updated 28 June 1999