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Risk assessment leads policy makers to conduct environmental impact assessments for new technologies or substances specific to each site, or for each medium (food, water, air) rather than establishing fixed and universal standards for emission and exposure. Thus as a result of risk assessment, higher lead emissions may be allowed at a rural facility where no other lead emissions are present than would be allowed at an identical facility in a polluted urban area where too much lead risk is already present.
In theory this process allows for flexibility in emission control strategies. It provides for the consideration of economic factors such as the cost of antipollution control programs. The goal is to avoid unnecessary expenditures where they would not result in a significant reduction of risk.
Risk assessment can allow policy makers to ask and answer the difficult question, "Where can I get the most benefit (reduction of risk) with a limited amount of money?"
Weapons in Chuboksary by Randy Kritkausky After the signing of the 1992 Chemical Weapons Treaty with the United States, the Yeltsin government quietly decided to transport all of Russia's chemical weapons to Chuboksary and two other cities where they were to be incinerated. But their plans were to be dammed, like the Volga River, at Chuboksary. The obstacle was a green movement led by Venera Pechnikova.
Venera Pechnikova spent much of her early adult life working on the banks of the great Volga River in the Chuboksary ChemProm factory. This installation produced a variety of chemicals, including chemical weapons from 1972-1987. ChemProm is located just below a sixty five meter high hydroelectric dam on the Volga. Venera was the head of the division of Technical Documentation in ChemProm. She was shocked that workers accepted inadequate safety measures without protest. Instead of working in disposable suits for two hour shifts, like their American counterparts, Russian workers wore rubber gas masks, rubber gloves and hot rubber suits for a four hour shift. At the end of a shift, workers poured the sweat out of their suits and washed them. Protective clothing was reused as many as fifteen times before being discarded, or else it would be discarded when it failed an air pressure test.
Evidently this method of identifying equipment failure after the fact rather than preventing failure resulted in frequent chemical exposures. But medical treatment was difficult to obtain. The factory's chemical weapons mission was top secret. Workers had to sign a pledge of secrecy. Doctors signed non-disclosure agreements which prohibited them from giving a diagnosis of exposure to chemical weapons. Since nerve gas was produced at ChemProm, many of the exposed workers suffered neurological and even brain damage. The latter victims' diagnosis was often given as schizophrenia, a label which allowed their complaints to be ignored. Consequently only a few workers, nineteen, were referred to a special facility in Leningrad for treatment. Tellingly, after the chemical weapons issue was discussed publicly, over two hundred workers were treated.
Venera Pechnikova's familiarity with chemical dangers, and her empathy with the chemical workers, is based on her own experience. As a university student, she was involved in a laboratory chemical accident when three liters of 250 degree Fahrenheit acid exploded over her hands and face. Doctors did not expect her to live. Venera credits her survival to the fact that she is a very determined woman and also that she was an athlete with a strong heart. Her recovery required a year in the hospital, eleven operations, radiation and liquid nitrogen therapy, and plastic surgery.
The pain and disfigurement of an acid accident and the subsequent treatment could discourage most people from engaging in public life. Venera remembers walking in public with her beautiful young daughter and hearing comments to the effect that the child must be adopted. But this woman, who was called "the iron woman" in her local press, became involved in community activities such as the Women's Council, Anti-Alcoholism Council, and Memorial Protection Society. In 1987 she was nominated by the Women's Council to run for office on the Chuboksary City Council, and was elected. In 1990, she was nominated to the Supreme Council of the Republic of Chuvashia. Residents of her City Council district organized a broad based campaign and went door to door seeking votes. Vera simply promised to work for their interests and to seek laws protecting them. She defeated her opponent, the Deputy Mayor of Chuboksary, who had made ambitious promises to the voters.
Once in the parliament, Venera became a member of the environmental subcommittee. She sought this position, before she became a dedicated green activist, because of rumors that chemical weapons would be disposed of in Chuboksary. Such information did not come from local officials, who were negotiating in secret. In fact no public decision making was planned; no environmental impact assessment was to occur. Fragmentary information came from Moscow News, from individuals in Russia who risked prosecution for disclosing secrets, and from Russian and foreign non-governmental organizations who described chemical weapons destruction problems in the United States.
While Chuvashian governmental officials met secretly in Moscow to arrange for the incineration of chemical weapons in Chuboksary, they blocked Venera's attempts to raise the issue in Parliament. However, Chuvashian law requires that an issue be discussed in Parliament if 10,000 signatures of support are gathered. Local greens gathered 17,000 signatures. Venera Pechnikova, the only speaker, was granted just twenty minutes to address the sensitive issue. She explained how the weapons would be transported, stored, and incinerated. She explained that in the United States chemical weapons destruction had taken place at the Johnson Atoll, far from population centers, and reminded her colleagues that Chuboksary was one of Russia's most densely populated regions. Following Venera's speech there was a vote. Of the one hundred and sixty parliamentarians who voted, one hundred and forty five voted against the chemicals weapons disposal plan.
Despite the vote, Chuvashian officials continued their negotiations with Moscow. In January 1993 Venera arranged to travel to Moscow in an effort to present her case to the Russian Parliament. She was allowed to make a formal presentation to a Parliament subcommittee. The hearing room was packed with ten front rows of military officials. During her Moscow visit, some sympathetic Russian Parliamentarians told Venera that the plan to dispose of weapons in Chuboksary would have been abandoned had it not been for the continued support of high level Chuvashian officials from the executive branch of government.
Chuvashia's Supreme Council, the republic's parliament, soon thereafter proposed a new environmental law including a provision banning importation of chemical weapons into the region. In response, Moscow officials began to argue publicly for weapons disposal and to offer economic incentives to Chuboksary. Nevertheless the law opposing importation of chemical weapons was passed, with one hundred thirty in support and forty opposed.
At this point the KGB became interested in Venera's work. Her telephone began to act strangely, but KGB agents kept a low profile until Venera began to have routine contacts with foreign journalists. Then the KGB explained to her that this was not an issue for outside involvement.
When President Yeltsin visited Chuboksary and ChemProm, chemical weapons negotiations were not mentioned as a reason for his visit. But local greens greeted him with banners announcing, "We know why you are here. We are against the destruction of Chemical Weapons here."
During her struggle, Venera began an association with the "Eco-Parliament". It is an unofficial intergovernmental coordinating organiza-tion founded in 1991 and is centered in Volgograd. It includes representatives of the governments of 25 republics and is interested in promoting environmental issues. In July of 1993 they voted to ban chemical weapons destruction as it was then proposed. While unofficial, the action marked a high point in the mobilization of public opinion against the chemical weapons incineration proposals in Russia.
As a result of the work of Venera Pechnikova and other green activists, a Russian Chemical Research Institute is now examining safer means of transport, storage and disposal of chemical weapons in Russia.
Author's Post Script
I met Venera Pechnikova in Atlanta Georgia, in February
1995. She was a participant in the workshop on Chemical and Nuclear
Contamination in the Former Soviet Union, held at the annual
conference of the American Association for the Advancement of
Science. My enduring memories of the Atlanta conference will be my
encounters with Vera and another activist, neither of whom hesitated
in the face of uncertainty or even risk to their own lives.
My second encounter with an activist occurred a mile from
Atlanta's skyscraper urban core in an African American (Black)
neighborhood. I met an old memory a few hundred meters from the
Ebenezer Baptist Church where Dr. Martin Luther King Jr. began his
career as an activist. I first encountered Dr. King twenty seven years
ago, at an anti Vietnam War demonstration in New York City where
he passed on the way to the speakers' platform some thirty feet from
me, an anonymous college student. As I stood once again thirty feet
from Dr. King and his tomb, I was thankful that there are such
individuals who place a high premium on the concept of social justice.
Walking back to the conference center in the middle of
Atlanta I was reminded of the difference between those who live in
"the main stream" and have the luxury of acting only when they have
absolutely determined all of the pertinent facts, and those who lack
power and must act or even risk their lives while acting upon
incomplete and uncertain information.
Despite the fact that a common concern with solving serious or even deadly environmental problems unites them, these actors in the decision making process commonly find that they cannot begin to agree on solutions. No sooner does the discussion begin than it appears that everyone is looking at the problem from a radically different perspective, especially as concerns the perception of risk. For fifteen years, my work as a local environmental activist has led me to the conclusion that this divergence of views is a logical result of an unresolvable conflict of economic interests: citizens simply want more protection than industry and government want to pay for. I also began to suspect that citizens, scientists, and policy makers were unable to communicate clearly because they are products of distinct subcultures and speak different languages.
While all of the above factors may be important, I have recently come to understand that much of the acrimonious disagreement that surrounds public participation discussions has a simpler origin. It involves the unacknowledged conflict between fundamentally different views of acceptable risk. I hope that by identifying this problem, it may become solvable.
For example, when discussing the health effects of the Chernobyl accident, a representative of the International Atomic Energy Agency (IAEA) insisted on using "deterministic" criteria (clinical evidence based upon nearly certain cause and effect relationships following immediately upon the accident).
The IAEA representative rejected "stochastic evidence" (cause and effect associations based upon probabilistic relationships occurring either shortly or long after the accident). He therefore dismissed all statistical epidemeological evidence of illness or death related to Chernobyl as unscientific.
Similarly, scientific consultants working for the Chlorine Chemistry Council of the Chemical Manufacturers Association sought to ensure that health assessments associated with chlor-organic compounds like pesticides, plastics, and dioxin are "scientifically grounded", a concept that they then defined as based upon a "full weight of evidence approach".
In practice, this approach resembles the clinical burden of proof demand made by the IAEA official. For example, when addressing the controversial U.S. Environmental Protection Agency (EPA) reassessment of dioxin, the Chlorine Council criticized the EPA for relying upon "animal data rather than available human data" and for using a model of human dioxin exposure "which has not been validated by experiment." Both the International Atomic Energy Agency and the Chlorine Chemistry Council spokesmen at the AAAS convention invoked the most stringent scientific criteria of proof of risk when evaluating risks associated with existing facilities or products.
Confusion entered into the discussion of health risk assessments at the AAAS meetings when there was a change in the level of scientific certainty demanded by participants from the scientific and policy making community. This was demonstrated by scientists who vehemently opposed a Greenpeace proposal to employ "precautionary" risk assessment criteria for chlor-organic compounds. (Chlor-organic compounds are chemical compounds with chlorine atoms attached to an organic molecular structure such as benzene or ethylene. Examples include many pesticides and plastics.) The Greenpeace proposal was the focus of the day long "World Without Chlorine" seminar. Greenpeace argues that chlor-organic compounds are too persistent in the environment and are too harmful to be permitted for use based solely upon statistical risk projections which extend permits to whole families of compounds whose characteristics vary widely. According to Greenpeace, such compounds should be subject to precautionary risk assessment. In other words they should be considered harmful until they are proven to be environmentally safe.
Opposing the Greenpeace proposal were industry scientists and many academics who prefer the present method of risk assessment. This method generally assumes that a chemical or substance is harmless unless proven harmful. They thus exhibited a willingness to accept an extraordinarily high level of uncertainty about the toxicity of new chemicals, nearly 100% uncertainty in the case of many of the more than one thousand new chemicals entering the market place yearly. This was a remarkable and confusing reversal of their position that toxicity assessments be based upon clinical evidence and that only such evidence should be used in policy making .
Such inconsistencies in establishing the ground rules for discussion of risk and the burden of proof for toxicity could be expected to disrupt communications between the concerned public on the one hand and scientists and policy makers on the other. Adding to the confusion, scientists and policy makers infrequently take the time to explain their disciplinary perspectives in general terms to the public. Even more rarely, if ever, do they discuss their assumptions concerning burden of proof. Consequently, members of the public often view the resulting changed expectations about the burden of proof as tricks and betrayals. Thus much public participation in environmental policy making never gets beyond a debate about who is telling the truth about risk and what the risks really are. Paradoxically, while this debate is often highly emotional on both sides, debates about calculating risks are profoundly scientific and should be at least partially resolvable within a scientific framework.
For example, in the debate over the toxicity of chlor-organics, Greenpeace is attempting to represent the public interest. In the process of evaluating the potential toxicity of new compounds Greenpeace demands that scientific proof be certain. The same reasoning is used by citizens who live near a proposed site for an incinerator, chemical weapons disposal installation, or landfill. They demand clear and highly certain scientific evidence of safety before accepting any new risk.
On the other hand, when there is public discussion about the connection between existing sources of potential pollution and local health problems, the public does not accept the burden of absolute proof. Those who live in a chemically polluted area do not want to wait until the causal connection between their children's ill heath and a leaking hazardous waste landfill is clearly and clinically established. They see a probable connection as a sufficient cause for action. In such situations the public is intolerant of risk, and is willing to act upon scientific uncertainty.
The diagram below summarizes the pattern of different people's response to risk: the general public as opposed to the majority of scientists and policy makers.
Type of Risk Assessment Preferred Criteria of For Evaluating Proof Existing Hazards Proposed New Plants or Substances Probabilistic Public Industry Deterministic Industry Public
Despite existing opportunities for delay, the current United States Congress is proposing new legislation, the "Risk Assessment and Cost Benefit Act of 1995" which could be used to delay environmental laws and standards even further. This bill requires every single law or regulation having a potential economic impact of more than 25 million dollars to undergo a thorough risk analysis and a cost benefit analysis. (Cost-benefit analysis requires putting a specific dollar value on every possible expense associated with the implementation of a regulation, including human health costs, also putting a dollar value on every benefit, including recreational and scenic value, and then comparing the two.)
Most significantly, the proposed law also provides new and abundant opportunities for challenges in court. Critics of the law suspect that the new U.S. Congress, which has announced its intention to suspend all governmental rule making for a year, is using risk assessment and its potential for endless scientific debates to completely derail all environmental protection activities. In the United States in the near future, risk assessment could become a weapon and not a tool of environmental policy making.
An alternative which expedites risk assessment is a California law which, very significantly, was introduced by a citizen-initiated referendum in 1986. The Safe Drinking Water and Toxic Enforcement Act, "Proposition 65," provided industry with an economic incentive to cooperate in the process of concluding risk assessment studies and in setting quantified environmental standards. The California law required that all suspected toxic substances for which no risk criteria had been established would be classified as potentially carcinogenic after a certain date. All products containing these substances would have to be be clearly labeled as toxic and would be forced to compete in the marketplace with products not labeled as toxic. In order to avoid negative advertising and possible legal liability, California industries cooperated with the state government in creating standards for regulating toxic substances. Risk assessments were conducted on two hundred and eighty two chemical substances in just a few years. There have not been any court challenges of the risk assessments or of the resulting regulations. The California Environmental Protection Agency described the impact of the incentive program as "One hundred years of progress [by federal standards] in the areas of hazard assessment and exposure assessment." California standards are generally more strict, and provide more protection for the consumer, than do federal standards.
By comparison, the United States national program, which allows and may now encourage delays, has set only a small fraction of such standards in several decades of work. Risk assessment can work, if it is coupled with the needed decision making incentives.
Mr. Gonzales' introduction: "Hesitation seems to exist world wide with regard to activities involving Chernobyl Risk Debate, radiation and radioactive materials, and in particular towards using nuclear power as an alternative source of energy. Public perception of the effects of radiation is the root cause that, directly or indirectly, has negative effects on the acceptance of these activities.... Although the public perception is different, the levels of radiation exposure and the biological effects associated with them are well known and they certainly do not represent a health concern."
Definition of deterministic and stochastic effects of radiation: "Deterministic effects result from the killing of cells which, if the dose is large enough, causes sufficient cell loss to impair the function of the tissue..... For deterministic effects, assuming that the effect is reliably diagnosed, causality is always certain. Deterministic effects are uniquely caused by radiation exposure; they occur in a short time after the radiation. . . . Stochastic effects may develop a long time after an irradiated cell is modified rather than killed. For stochastic effects, on the contrary, causality is never certain in individual terms. . .The cause-effect linkage can be established only for populations as a whole, and even in this case the relation is uncertain."
On the stochastic projection of cancer rates for low dose radiation exposure: " ..the probability being an order of five per hundred thousand per mSv (millisevert, measure of radiation dose) for a working population and around seven per hundred thousand per mSv for the general population."
Question by Richard L. Garwin, Fellow Emeritus, IBM Research Center, based upon Gonzales' figures for projection of cancer rates.
" In your twenty three page paper I missed an important conclusion. And I wonder if you will agree as it can be drawn directly from your numbers. You say that the International Advisory Committee says that the total world wide dose to people is 600 Sv. You also say that there is a five/hundred thousand [sic] incidence of cancer predicted. Multiplying those two I gather that there will be 30,000 cancer deaths among the world population due to Chernobyl if we believe those numbers. Within the former Soviet Union the corresponding calculation will be 12,000. Do you agree with that conclusion?"
Response of Gonzales: "This is a trap, and I will tell you why. It's a trap because that number is a conservative number developed for radiation protection purposes. But we have been unable to experimentally prove that number. There are many people who believe that after the initial effect of radiation upon on the cells, the [human body] has repair mechanisms much more effective than we thought. An UNSCEAR (United Nations Scientific Committee on the Effects of Radiation) study, called "Adaptive Response," showed clearly that a cell has a repair mechanism that is more and more and more efficient as radiation goes up. Therefore we do not know with certainty. I am O.K. using that number for design purposes. . . But to use that number to estimate that 30,000 people have died, that I have not seen, that I cannot detect, is really a trap. Maybe it is true, maybe it is not. It is irresponsible to say, with absolute certainty, that 30,000 people have died. I cannot measure it. I can not establish causation for this."
Gonzales on the topic of public perception of radiation risk: "Contrary to what facts seem to indicate, public perception of radiation exposure is that it has devastating health consequences. It is difficult to understand such a wide gorge between the objective scientific information and the actual perception of it... Or is it just self-interest (very nice but not in my backyard, please!)"
On the health effects of the 1986 Chernobyl accident: "The UNSCEAR assessment shows that on a global scale, the total radiological impact of Chernobyl has been minor in technical terms. This amount is about five percent of the global collective dose delivered by natural sources each year."
Summarizing the findings of the International Chernobyl Project: "no health disorders were detected in the affected population that could be directly attributed to radiation exposure. . . .Thirty workers died and two hundred were overexposed."
Risk assessment is often presented as a rational and more comprehensive alternative to establishing rigid norms and emission standards. From the perspective of risk assessment, siting an incinerator in a remote rural area with clean air may be viewed as less of a risk than siting the same facility in a densely populated area or in a region where the ecosystem is already weakened by high levels of pollution. Using the logic of risk assessment, fewer emission controls may be imposed upon a facility sited for an area where little pollution presently exists. This may make sense from an economic point of view, if scarce resources will then be made available for pollution reduction in more heavily impacted areas.
Unfortunately however, this logic has the unanticipated consequence of encouraging the siting of very polluting or dangerous facilities in highly pristine environments where little previous damage has occurred and where the local ecosystems and population are assumed to be capable of absorbing risks comparable to those found in more industrial zones.
Residents of rural Northeastern Pennsylvania, the site of ECOLOGIA headquarters in the United States, have struggled with this dilemma for decades. A strong grassroots environmental movement has kept potentially polluting industry from coming into the area. Consequently, the water and air in the region is of extraordinarily high quality. But, to the continuing frustration of local environmentalists, the more they succeed, the more economically attractive their region becomes for polluting companies, since risk assessments and environmental impact assessments assume that a clean environment can tolerate more pollution.
For this reason, the practice of risk assessment may be tempered with another environmental policy making principle, implementation of the Best Available Technology (BAT). The principle of BAT argues that maintenance of environmental quality is a higher priority than minimizing pollution abatement costs. Rather than loading the environment to a predetermined acceptable dose and risk level, the BAT approach argues that every effort should be made to minimize environmental degradation.
Risk assessment is presently conducted separately on individual facilities, radionucleides, and chemical compounds. The process normally assumes that one risk does not interact with another. The interactive effects of compounds are frequently ignored. However, there are many examples of risk caused by such interactions, or synergistic effects. For instance, chlorine is added to public water supplies to kill bacteria. However, chlorine reacts with solids (suspended particulates) in water to create trihalomethanes, which are proven carcinogens.
Such complexity is not sufficient reason to reject the process of risk assessment, but it is reason to require that such interactions be identified and evaluated.
Environmental risks are often compared to those posed by existing background levels. This is most common in the field of radiation risk assessment. However, risk assessments are frequently used to argue for elevating levels of regulated substances just slightly over the existing background levels increase. For example, the background levels of radiation and dioxin in much of the world are now very much higher than a few decades ago.
At some point, perhaps in our past for many substances, it is reasonable to question whether or not background risk has itself become risky.
Risk assessment is a logical outgrowth of the 18th century Enlightenment: science was thought to be the means by which mankind could understand the natural laws of the universe, master nature, and engineer a perfect society. In this two hundred year old spirit, those who conduct risk assessments assume that the natural systems they investigate are orderly and sufficiently stable so as to be highly predictable. They assume that any minor variations in the biological systems they are evaluating will have insignificant consequences upon the final calculations of risk for that system.
Modern science is however reexamining many of its notions about the stability and predictability of complex systems in light of chaos theory. Chaos theory has focused its attention upon complex systems where minor perturbations may produce radical changes. The weather is a classic example. Minor changes in one region may have significant and unpredicted impacts half a continent away. This concept has given rise to the now famous concept of the "butterfly effect".
In chaos theory, the simple agitation of a butterfly could, under the right circumstance, affect the direction of the wind if we assume that the butterfly flew through a perfectly but precariously balanced weather system. The mild perturbation of the butterfly's wings could change the entire system. (This example is meant to be an exaggerated illustration of a principle, not a highly likely real world event.)
The general public has long had an intuitive grasp of the conclusions of chaos theory. It knows that an extremely low probability event can have disastrous consequences for the systems in which normal people live. Ordinary people are accustomed to observing dramatic changes in the often unstable and precariously balanced economic, social, and biological systems in which they live. These changes are often precipitated by small outside forces. Minor changes in interest rates impact business investment and employment. Small shifts in demographics, such as a slightly younger population, dramatically impact crime rates. New hunting and fishing technologies precipitate dramatic changes in wildlife or fish stock. Therefore, in calculating risk and accepting risk predictions, the public has intuitively embraced the concept of "the butterfly effect" - rooted in an awareness of the instability of the universe - while traditional scientists have assumed a more orderly, more predictable, and more manageable world.
Perhaps it is time for risk assessors to be more open about the inherent uncertainties in their work. They should begin to develop models which publicly acknowledge and quantify the potential impact of low probability but potentially devastating events, like nuclear power plant accidents.
A classic example of the clash of science and public perception occurs in the arena of comparative risks. Homicide, drug abuse, auto accidents, and suicide create enormous anxiety among the public. However, in the United States, all of these problems together cause fewer deaths yearly than does cigarette smoking. The daily world death toll from smoking is an estimated 8,200. In theory, the cost of eliminating Rational Risk Assessment, con't from p. 9 this risk is minimal as the problem is 100 percent preventable. But cigarette smoking has been, to a large degree, a culturally accepted risk.
Consequently, among European environ-mentalists there is relatively little attention directed toward eliminating the risks associated with smoking, while comparatively enormous time, energy and resources are invested in health issues associated with landfill pollution, high voltage electrical transmission lines, and food additives. In a world where environmental organization fund raising is partly dependent upon maintaining a high level of public concern about environmental health and safety, dispassionate analysis of risk and the comparison of risks is an essential, though potentially unpopular, ingredient of good policy making.
Risk assessment, for all of its scientific pretensions of objectivity, is still essentially a political process. It functions as part of a political process and its results reflect power relationships as much as "objective truth". Risk assessment works only where there is meaningful public participation in environmental decision making and where there are effective checks and balances placed upon scientific claims to the truth. Otherwise "risk assessment " can be used as a tool of technocratic rule: rule by a technically trained elite who are not responsible to the public, and not controlled by democratic processes such as checks and balances or elections.
There is an enormous temptation to escape from the time consuming and often tedious debates of democratic decision making and flee into the arms of technocracy. Recently ECOLOGIA hosted a group of visitors from the Former Soviet Union. After a two day workshop on an environmental decision making model for selecting clean up technologies, one of the participants noted that as a public official he would welcome such a "scientific approach" as it it would free him from making the final decision and insulate him from the complaints of the public and industry. He was disappointed to be reminded that the decision making model only presented options and their consequences. Policy makers still had the responsibility of choosing among the options.
Science is a neutral forum for determining facts, evaluating and comparing some of the consequences of specific decisions. To the degree that risk assessment can contribute rationality to the decision making process, it can be an important tool. It is not however the entire solution.