Risks of Risk-Based Decision Making. Jo
Anne Shatkin, Menzie-Cura & Associates, Inc., 1 Courthouse Lane, Suite 2,
Chelmsford, Massachusetts 01824, USA, telephone 508-453-4300, fax 508-453-7260,
e-mail JASHAT@aol.com
Various
state and federal United States policies for setting cleanup standards for
contaminated property are increasingly being established through risk-based
methodology, rather than setting the standard to a pristine condition. This
approach allows sites to be cleaned up to a standard that is protective of human
health, rather than to background levels, which is often infeasible and/or
costly. The risk-based approach offers flexibility in setting cleanup levels and
is considered crucial to many urban economic revitalization initiatives,
popularly called Brownfields, that can include placing limits on uses of a
property to avoid risks associated with exposure to site contaminants.
The
risk-based approach breaks down when background levels of contaminants are
higher than would be determined through quantitative risk analysis because
contaminants are either naturally occurring or are ubiquitously high in an area.
Several issues are raised by this risk management approach: What contributes to
the elevated levels, and is incremental risk detectable in comparison to
naturally occurring levels of pollutants?
What
does it mean to implement a risk-based policy that is not necessarily protective
of human health risk?
Depending
on the contaminants of concern, different risk levels are applied to different
types of sites. Who pays and who benefits from this approach?
These
issues are addressed through evaluation of case studies. Alternative approaches
to establishing site-specific cleanup levels are evaluated using criteria of
fairness, health protectiveness, cost, and ease of implementation.
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