IUBio

IS THE GOVERNMENT GIVING TOXICOLOGISTS A BAD NAME?

Steven J. Milloy milloy at cais.com
Thu Oct 19 15:12:54 EST 1995


Presented is a synopsis of an important book. If you are interested in 
obtaining a copy, ordering information is at the end of the posting.


                                         CHOICES IN RISK ASSESSMENT:
                                      THE ROLE OF SCIENCE POLICY IN THE
                                    ENVIRONMENTAL RISK MANAGEMENT PROCESS


WHY IS CHOICES IN RISK ASSESSMENT IMPORTANT?

The Federal government estimates that it will take between $300 billion to over $1 trillion in
taxpayer dollars to clean up Department of Energy properties.  However, it is "political"
science, not analytic science that is forcing these vast expenditures and the decisions on what to
clean up.  As a result, it is very uncertain what benefits to the public and the environment will
be produced by these cleanups.  Shouldn't we be debating to what extent stealth-like, "political"
science should drive the spending of limited public resources?

WHAT IS CHOICES IN RISK ASSESSMENT ABOUT?

Choices in Risk Assessment is the first comprehensive discussion of the role of "political"
science, or "science policy," in environmental risk assessment and risk management.  Science
policy, including the so-called "default assumptions" is used to bridge the gaps in scientific
knowledge and data that arise in risk assessment.  Although advances in science are clearly
desirable and are occurring, they will not come soon enough to address the onslaught of real and
alleged, known and hypothetical, and significant and insignificant environmental risks
currently facing policymakers.  However, wider recognition and better understanding of the role
of science policy may improve the quality of risk-based environmental policies, mandates and
programs.

DOES THE FEDERAL GOVERNMENT HAVE A ROLE IN CHOICES IN RISK
ASSESSMENT?

Choices in Risk Assessment is a product of the Science Policy Impact Analysis Project which
was sponsored by the U.S. Department of Energy's (DOE) Office of Environmental
Management and Office of Environmental, Safety and Health, and tasked to the Sandia National
Laboratories.  The purpose of the project is to provide DOE with input to its activities that are
impacted by science policy.  The report was authored by the Regulatory Impact Analysis Project,
Inc., a nonprofit public policy research organization.  

WHAT ARE THE FINDINGS OF CHOICES IN RISK ASSESSMENT?

Based on input from government and nongovernment experts, and supported by analyses of
actual major regulatory agency actions, Choices in Risk Assessment concludes that:

1. Most environmental risks are so small or indistinguishable that their existence cannot be    
proven.  Most only exist because of policy, not scientific knowledge and data.

2. Science policy is necessary and permanent, yet it is inherently biased and is usually          
designed to achieve pre-determined regulatory outcomes and objectives.

3. The economic and social consequences of risk-based environmental regulation result         
directly from science policy decisions.

4. Policy makers, the media and the public are unaware of the role of science policy because 
of a lack of full and fair disclosure.

As a consequence, risk-based environmental policy is generally not debated or made on a
fully-informed basis. 

WHAT SOLUTIONS DOES CHOICES IN RISK ASSESSMENT RECOMMEND?

Only when the relative roles of science policy and analytic science are understood can the real
issue in risk-based environmental policy be debated. Society must decide how much it is willing
to pay to reduce or avoid risks that have been identified and quantified by science policy rather
than by analytic science.

If risks are too small or indistinguishable, it is not possible to know whether regulation will
produce benefits to society commensurate with its costs.  Open debate of the value and priority
of regulating these types of risks will enable, but not guarantee, environmental policy and
regulatory decisions to be made on a fully-informed basis.

CHOICES IN RISK ASSESSMENT SPECIFICALLY RECOMMENDS THE FOLLOWING:

1. Science policy should not be used to conceal the truth about the measure of uncertainty   of
environmental risk estimates.  Policy makers, the media, and the public should be made    
Aware of the role of science policy in risk assessment and subsequent risk management        
decisions.

2. Because science policy is often misused as uncontroverted fact, the Federal government  
should initiate mandatory training and continuing education programs on regulatory risk        
Assessment and management for its personnel.

3. Less emphasis should be placed on the need for risk assessment guidelines.  Although,    such
guidelines may provide a framework for the use of science policy if they are flexible and    are
complied with in good faith, they are not a panacea.

4. Precedent has been established, and agencies should be encouraged to give meaningful   
consideration to alternatives to the default assumptions.

Choices in Risk Assessment is not limited to Department of Energy issues.  The Federal
government will also be spending huge sums cleaning up Department of Defense, Department
of Interior and other Federally-owned properties. Moreover, state and local governments,
industry, and consumers incur enormous costs resulting from science policy-driven
environmental programs and mandates which produce unknown to, at best, few public health or
environmental benefits.

                COPIES ARE AVAILABLE FOR $15 EACH

    CONTACT: STEVEN MILLOY (202) 739-0186 or milloy at cais.com
 
                     1725 DESALES ST., N.W.
                            SUITE 700
                     WASHINGTON, D.C. 20036




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