It is time to change the traditional approaches to assessing
and reducing environmental, health, and safety risks, which have
relied on a chemical-by-chemical, medium-by-medium, risk-by-risk
strategy. That strategy evolved from multiple, unrelated
statutory requirements from the various Congressional
subcommittees that have jurisdiction over agencies responsible
for protecting health and the environment. The result is our
highly fragmented and adversarial system of conflicting actions
that ignores the interdependence of environmental components,
emphasizes the differences instead of the similarities between
cancer and other health effects, and investigates risks
associated with individual purified chemicals instead of
environmental mixtures of chemicals.
Many effective risk-management decisions certainly have been
made, but many other decisions have left stakeholders unhappy or
problems only partly addressed. Testimony received from the U.S.
Department of Energy (DOE) Office of Integrated Risk Management,
the U.S. Environmental Protection Agency (EPA) deputy and
assistant administrators, and the public repeatedly emphasized
the need to address multiple chemical exposures and called for
our environment to be addressed as a system, not as a fragmented
collection of individual risks. A related difficulty is the need
to combine characterizations of risks to health and the
environment with values, perceptions, and concerns of affected
parties, especially nontechnical people and communities.
Moving toward integrated, effective environmental management
requires a risk-management framework that can engage a wide range
of stakeholders and address the interdependence and cumulative
effects of various problems. The framework must have the capacity
to address various media, contaminants, and sources of exposure
and an array of public values, perceptions, and ethics. It should
be sufficiently understandable to be adopted and used by risk
managers in a wide variety of situations and lead to acceptable
and effective decisions. It should be flexible so that its use
can be matched to the importance of the decisions to be made.
Full implementation of the framework for federal programs will
lead to a need for Congressional authorization and funding;
however, much progress can be made with existing statutes.
The overarching goal of the Commission's framework for
integrated risk management is to move beyond
"end-of-the-pipe" command-and-control approaches to
environmental protection toward means of achieving sustainable
development. Such an ethic of environmental stewardship requires
an understanding of the connections between environmental health,
human and economic well-being, and the processes by which our
society's actions create long-term changes, both beneficial and
adverse.
The Commission believes that the integrated risk-management
framework described here is timely. It is consistent with
regulatory-reform goals of stimulating economic progress while
improving the effectiveness of environmental protection and
sustaining the accomplishments of the last 25 years of
environmental regulation. Thus, it is consistent with the goals
of the President's Council on Sustainable Development--to ensure
that every person enjoys the benefits of clean air, clean water,
and a healthy environment while maintaining economic prosperity
and creating full opportunity for citizens, businesses, and
communities to participate in and influence the natural-resource,
environmental, and economic decisions that affect them (PCSD
1996). Its insistence on collaborative stakeholder involvement
and empowerment, its commitment to place each problem in a
public-health context, and its use, when appropriate, in an
iterative manner to refine regulatory decisions make it
applicable to diverse environmental regulatory problems. Although
the Commission's mandate was to evaluate risk-management
decision-making at the federal level, the framework is applicable
to all levels of decision-making.
The framework reflects the importance of "participatory
democracy" in resolving environmental dilemmas (Ruckelshaus
1995). It is consistent with testimony calling for
risk-management partnerships among government, industry, and the
public. For example, Walter Fields, of the National Association
for the Advancement of Colored People (NAACP) in New Jersey,
urged the Commission to define specific steps needed to bring
communities into the risk-assessment and risk-management
processes and to enable communities to engage in honest dialogues
with industries. The Commission received similar testimony from a
variety of people all over the United States, including Michael
McCloskey, chairman of the Sierra Club; Linda Greer, of the
Natural Resources Defense Council; Mark Van Putten, of the
National Wildlife Federation; Peter Raven, of the Missouri
Botanical Garden; Ronald Selph, mayor of Granite City, Illinois;
Carol Henry, director of the DOE Office of Risk Management; and
Phillip Lewis, of Rohm and Haas Company, Philadelphia. The
framework incorporates various principles and recommendations set
forth by the Carnegie Commission report Risk and the
Environment: Improving Regulatory Decision Making, the
National Commission on the Environment report Choosing a
Sustainable Future, the National Research Council report Science
and Judgment in Risk Assessment, the Annapolis Accords for
Risk Analysis, the Harvard Group on Risk Management Reform, and
the National Academy of Public Administration report Setting
Priorities, Getting Results.
FINDING 2.1: After many years of management
of environmental, health, and safety risks in the United States,
there is still no generally accepted or uniformly applied
framework or set of principles for making risk-management
decisions. Current efforts to manage risks are often fragmented
and sometimes in conflict, often reflecting different statutes.
In addition, there is no systematic process for integrating
public values, perceptions, ethics, and other cultural
considerations into risk-management decisions.
RECOMMENDATION: A systematic, comprehensive
risk-management framework should be used to reduce environmental,
health, and safety risks. The Commission's framework comprises
six stages (figure 2.1): formulating the problem in broad
context, analyzing the risks, defining the options, making sound
decisions, taking actions to implement the decisions, and
evaluating the effects of the actions taken. The framework can be
used iteratively and must embrace collaborative involvement of
stakeholders.
RATIONALE
The Commission's risk-management framework constitutes a
comprehensive strategy for reducing risks to public health,
safety, and the environment. Each stage involves a different set
of questions. The following is a description of how the six
stages would operate and the collaborative and iterative
processes that would occur throughout them.
1. Problem/Context: What is the problem? What is
its context? Who is responsible for managing the problem, and who
are the stakeholders? A potential or existing problem might
be identified on the basis of environmental monitoring; emissions
inventories; disease surveillance and epidemiologic observation;
unexplained illnesses; a permit application; a bad odor; a need
for national standards to control contaminant concentrations in
air, water, soil, or food; or some other public concern.
Attention might be focused on a "symptom" of an
underlying problem.
The problem would be examined not just in a medium- and
pollutant-specific manner, but in a comprehensive, multimedia,
public-health context. Potential relationships among different
problems are identified and considered. For example, the
degradation of an aquatic ecosystem can be caused not only by
point sources of water pollution but also by nonpoint sources,
such as urban and agricultural runoff. It can also be affected by
land-disturbance activities, including logging and grazing,
construction of dams and reservoirs, diversion of surface-water
and groundwater flows for domestic and agricultural uses,
overfishing, and introduction of exotic species. Deposition of
air pollutants--such as nitrogen, lead, cadmium, chromium,
mercury, and radionuclides--can also contribute to the problem
(see section 6.1.4).
Stakeholders are identified at the problem/context stage and
are relied on heavily for problem identification and
characterization. Risk managers can be people or institutions at
the federal, state, or community level, depending on the
problem's context. Once there is collective appreciation of (and
possibly consensus on) the characterization of the problem,
risk-management goals and objectives can be defined and pursued.
Appropriate contexts for a problem are likely to be
situational. In some cases, the context can be overall public
health. In other cases, it might be other risks (see section 5.1
for a discussion of risk comparisons). In still others, it might
be its relationship to the interdependence of different problems
(such as the degradation of an aquatic ecosystem, as described
above).
An example of formulating a problem in its context might start
with the consideration of the risks associated with hazardous air
pollutants regulated at one industrial facility or category of
facilities in the context of risks associated with stationary and
mobile sources that emit the same pollutants in the same
geographic area. The next layer of context would be comparisons
with risks associated with other important air pollutants, such
as particles and carbon monoxide. A multimedia context would lead
to a comprehensive plan that includes risks associated with air,
water, and solid waste in the region.
Putting a problem in its context will be needed when residual
risks associated with hazardous air pollutants are characterized
after technology-based controls are implemented under the Clean
Air Act (see section 6.1.1). For example, EPA has promulgated a
maximum-available-control-technology (MACT) standard for the
petroleum refinery industry. That standard was promulgated partly
on the basis of EPA's finding that emissions from petroleum
refineries potentially pose a leukemia risk to exposed
populations because they contain benzene, a known human
carcinogen. The standard will reduce the emissions of benzene and
other hazardous air pollutants emitted by the source category.
After the standard is implemented, residual-risk assessments will
include a calculation to determine whether a leukemia risk that
can be attributed to benzene remains. In addition to being
emitted from petroleum refineries, benzene is emitted as exhaust
from motor vehicles. In fact, emissions from mobile sources
represent the largest single source of airborne benzene in the
United States. Residual risks associated with the benzene emitted
from a particular petroleum refinery could be compared with those
associated with benzene from mobile sources and any other
important sources that might exist in the geographic area of
interest, including consumer products used in the home. The
advantage of considering the risk in that context is that if the
residual leukemia risk contributed by the petroleum refinery
proves to be significant in comparison with the leukemia risk
contributed by other sources, risk-reduction efforts can be
focused on modifying the refinery further. If it proves
insignificant in comparison, more effective and more efficient
means of risk reduction that focus on the larger contributors of
risk might be possible.
2. Risks: What risks does the problem pose to
public health? Risk would be determined by considering the
nature, likelihood, and severity of adverse effects on human
health, the environment, or public welfare (such as economic
well-being or aesthetics). Risks would be evaluated primarily by
scientists and risk managers with input from stakeholders.
Community stakeholders should be consulted at this stage to help
to identify groups with high exposures so that appropriate
exposure assessments can be designed (see section 3.2). The
factual and scientific basis of the problem would be articulated
and incorporated, along with subjective perceptions of the
problem, into a characterization of the risks to human and
environmental health and consideration of cultural and societal
values, quality of life, and environmental equity (see section
5.1). Health and ecological risks would be treated both
qualitatively and quantitatively. The nature of the adverse
effects, their severity, their reversibility or preventability,
and the possibility of multiple effects must be understood before
complex estimates of the magnitude of the risks and their
uncertainties are presented (see section 3.5). Cumulative risks
associated with related problems would be identified, where
possible. Indirect effects on human health through disruption of
the environment also would be considered.
3. Options: What can and should be done about the problem? What are the potential consequences and expected benefits of intervention? Are there other ways to reduce similar health effects in the same population or similar ecological effects in the same region? What are the estimated costs of each option? Approaches to addressing the problem would be identified by stakeholders, regulators, and scientists. A variety of regulatory and nonregulatory alternatives would be considered, such as permits, enforcement actions, pollution prevention, recycling, market incentives, voluntary reductions, and education (see section 5.4). Institutional, financial, and other arrangements for implementing each approach would be identified. The extent of risk reduction expected and the relationship between the costs and benefits of each approach would be determined and compared (see section 4). Cultural, ethical, political, and legal dimensions would be considered. Potential impacts of each approach would be characterized, including possible adverse effects on workers, the community, or the environment.
4. Decision: What is the best solution to the
problem? How can that decision or set of decisions be reached?
Who should make that decision? Will the actions required be
compatible with the Unfunded Mandates Act of 1995? The most
feasible, effective, acceptable, and cost-effective approaches to
mitigating the problem would be identified, with the
participation of affected and responsible parties. A mechanism
for conflict resolution, or for reaching closure in the absence
of consensus, might be needed. It is important to acknowledge
that this framework will not always result in a consensus among
those involved in the process. In fact, participation,
negotiation, and attempted compromise sometimes can result in a
hardening of opposite positions, a breakdown in negotiations,
frustration with the process, and an inability to reach
agreement. Those difficulties in reaching a decision should be
viewed not as a failure of the process envisioned by the
framework, but simply as a recognition that in some instances,
notwithstanding the best efforts of all affected parties,
consensus will not be achievable. At some point, the responsible
regulatory authority must make its decision, including a decision
to defer, if opposition is too strong or too credible. Deferral
would require a later decision of whether to repeat the process
from the beginning or to go on to other pressing needs.
5. Actions: How can the decision be implemented
rapidly and flexibly? The action that has been chosen to
address the problem is explained and taken. Several actions might
be needed in various circumstances. Actions might be taken by
public agencies, businesses, industries, and private citizens,
alone or in combination. Objections or reassessments, even at
this stage, may trigger an iteration of the process.
6. Evaluation: How effective are the actions?
Too often, actions are mandated but there is little followup to
ensure that they are taken, to analyze effectiveness and cost, or
to compare the findings with estimates made in the
decision-making stage. The effect of a chosen action on the
problem can be characterized through monitoring and surveillance,
through discussions with stakeholders, and through analyses of
relationships between interventions and trends in health or
environmental indicators. Criteria should be specified in
advance. On the basis of evaluation, the original problem can be
redefined, the actions reconsidered, and the various stages
repeated if appropriate.
If the evaluation of the impact of the actions on a problem
finds it unsatisfactory, another iteration of the process might
be needed. But few effects on risk lend themselves easily to
measurement and validation. To some extent, monitoring and
surveillance can enable the study of relationships between action
and effect, but often such relationships are detectable only when
the margin between actual exposures and exposures associated with
the health or ecological effect of concern is narrow or the
health effect of interest is particularly rare. Most
public-health risks are already low, compared with such
measurable effects as occupational injuries or motor-vehicle
collisions. For example, suppose an action lowers the lifetime
incremental risk of developing cancer because of a particular
exposure from 1 in 10,000 to 1 in 1,000,000. No health study or
surveillance activity could be designed to measure the
effectiveness of an action with such a small change, because
cancer would be the cause of death in 24% of the population in
either event. Conclusions about effectiveness in such a case
would have to rely on environmental monitoring, changes in
biologic markers of exposure, or some other indirect measure of
impact on disease incidence. Developing good baseline and
surveillance information about disease incidence, linking health
and environmental data, and determining regional differences in
disease prevalence, trends, and risk factors would improve the
ability to implement effective public-health interventions and
enhance our confidence that they are effective.
The Commission's framework is intended to be implemented
collaboratively, with some level of participation of stakeholders
or other affected parties at each stage. Figure 2.1 shows a
particularly prominent role for stakeholder involvement in the
first stage, formulating the problem in context. Such
partnerships can facilitate the exchange of information and ideas
that all parties need if they are to make informed decisions
about reducing risks. Regulatory actions or decisions are more
likely to be successful if affected parties are involved in
scoping and decision-making than if they are not (Richards 1993).
As NAACP representative Walter Fields testified at the
Commission's meeting in New Jersey, if people are not included in
risk-management decisions, such as facility siting, from the very
start, they feel excluded from important decisions that affect
their communities, and emotional, not rational, reactions govern
their response. The importance of stakeholder participation was
emphasized by the President's Council on Sustainable Development
(PCSD 1996) and the National Research Council Committee on Risk
Characterization (NRC 1996a).
Including stakeholders in the processes of defining a problem
and assessing its risks can provide a forum in which to clarify
the technical data and science-policy assumptions used in risk
assessment. Our recommendation for serious involvement of
stakeholders in active protection of ecologic and human health,
especially at the community level, is well-supported by recent
public-opinion poll results. For example, results from a survey
in mid-March 1996 suggest that 80% of Americans think that
government at all levels should encourage citizen involvement in
health and environmental protection (Council for Excellence in
Government 1996). They do not want government to do less about
risks to health and the environment than it does currently, but
they want government action to be more efficient and effective.
They also think that responsibility for controlling risks should
be shared by government, business, communities, and individuals.
Collaboration also plays a central role in effective
implementation, especially if environmental protection is no
longer considered solely a government-industry responsibility and
the public is expected to participate directly in implementation
of risk-management steps (McCallum and Santos 1995). Public
actions include reduction and recycling of wastes at home, on
farms, in offices, and in recreation, as well as bearing some of
the cost. Public comment and public meetings are not adequate
substitutes for collaborative approaches to problem-solving,
although they can be useful in gaining broader participation.
Effective stakeholder involvement in regulatory decision-making
requires a shift in attitudes so that affected members of the
public are seen as partners in the problem-solving process,
rather than as obstacles to it (Van Horn 1988, Chess et al.
1995). It might also require a modification in the timelines that
regulatory agencies must satisfy to meet statutory or
court-imposed requirements.
A potential disadvantage of our framework might be the
investments of time and money required to implement a
collaborative, systematic process. Even if the process might lead
to long-term savings, the up-front costs could be considerable.
Moreover, there is no guarantee that consensus on a
risk-management decision will be reached. However, the time and
expense required are unlikely to exceed the experiences of the
Occupational Safety and Health Administration and EPA, which have
sometimes required years in preparing agency risk assessments, in
notice-and-comment rule-making, and in litigation over the
resulting decisions.
Implementing a collaborative decision-making process should
include incentives for participation. An industry or municipality
might be more inclined to participate willingly and cooperatively
if it were to receive some relief in exchange, such as reduced
reporting requirements, suspension of punitive damages, or
elimination of parties' abilities to sue after a decision is
reached.
The framework is intended to be implemented iteratively; that
is, the process can be refined and its conclusions can be changed
on the basis of research, new data, and new views. Iteration
could apply to a rule that has already been promulgated or to a
new rule or a new approach to a problem that is being developed.
Public comment, negotiation, or analysis can redefine the problem
or identify other issues of concern in a broader context.
Research and information-gathering performed to clarify a problem
or a risk might lead to a focus on a somewhat different problem.
Analyzing risks and options can lead to a better understanding of
how a problem should have been defined and scoped at the outset.
However, iteration must not be allowed to become a device for
indefinite delay. Using an iteration to scope a problem might
actually speed up the risk-management process, as goals and
issues are clarified, and possibly lead to a quicker and more
cost-effective resolution than expected initially if it becomes
apparent that proceeding with the entire framework is no longer
necessary.
The proposed framework is intended to be a guide for an
approach or thought process for risk-management decision-making.
It is unlikely that all aspects of the framework would be
required for every problem and some might be inconsistent with
certain statutory requirements. Different levels of
decision-making will require different levels of analysis. Risk
managers should apply this process flexibly to accommodate the
needs of individual circumstances.
A number of criteria might be used to determine when applying
the framework would be most useful. A problem worth addressing
according to the framework should involve achieving an
agreed-upon goal, the optimal path to which is controversial. The
problem should require resolution of interdependent or related
issues. Enough facts should be available to permit meaningful
discussion and resolution. Participants in the process should be
representative of those affected by the outcome of problem
resolution. In some cases, it might be particularly important for
elected officials or their representatives to be included in the
process so that their support of the result is likely. For
example, including members of Congress in the stakeholder
deliberations about Superfund reauthorization in 1994 might have
enhanced the prospects for the success of that effort.
The framework can be applied at several levels.
National level. Congress could apply the integrated,
multimedia approach of the framework to its future
risk-management legislation and to its oversight of existing
agency programs. For example, Congress could modify the Clean
Water Act to establish a comprehensive, integrated, multimedia
watershed-management approach and to provide for the development
of state watershed programs (see section 6.1.4). The current EPA
watershed-protection approach could be expanded with additional
authorization and funding from Congress to accomplish multimedia
environmental-risk management under the Clean Water Act and
possibly under the Clean Air Act. In fact, using the current
watershed-protection approach, EPA-sponsored estuary programs in
Tampa Bay and Galveston Bay are good examples of how state and
local governments and citizens can participate in a process that
identifies high-priority, multimedia environmental problems and
take action to ameliorate the problems.
EPA can use the framework to support its development of an
integrated air-toxics strategy for urban areas, to link decisions
on residual risks from major sources with risk-driven decisions
on smaller stationary sources and mobile sources. Section 6.1.1
has a detailed discussion of the application of the Commission's
risk-management framework to the determination of residual risks.
EPA can also use the framework to support its Common Sense
Initiative to integrate all the permitting that is required of
individual manufacturing facilities, overcoming conflicting and
redundant requirements.
State and regional levels. Under existing federal and
state laws, states and regional airshed or watershed authorities
can use the framework approach to address various environmental
problems in an integrated manner, where applicable and feasible.
Both the Michigan Department of Environmental Quality and EPA
Region 5 have organized themselves into multimedia teams to
facilitate integrated approaches to risk management. Several
states have initiated programs to resolve and integrate
potentially conflicting permitting requirements.
One example of how the problem/context and risks stages of the
framework could be applied at the state level is the case of
oxygenated and reformulated fuels. The 1990 Clean Air Act
Amendments required that new vehicle fuels be introduced by 1992
in communities with of carbon monoxide concentrations exceeding
national ambient air-quality standards. The new fuels contain the
additive methyl tert-butyl ether (MTBE). In some
states--particularly Alaska, Montana, Wisconsin, and New
Jersey--there have been numerous complaints of unexplained
symptoms of health effects. More that 70 million Americans are
potentially exposed to evaporative emissions from oxygenated and
reformulated fuels. MTBE has been singled out as potentially
responsible for the symptoms. Assessing potential risks
associated with these fuels in a public-health context should
include evaluating not only MTBE toxicity but also risks
associated with increased concentrations of nitrogen oxides,
formaldehyde, and acetaldehyde. The health benefits of the
MTBE-related reductions in carbon monoxide and benzene
concentrations would also have to be considered, as would the
role of ambient temperature and engine performance in exposures
(HEI 1996). The risk characterization should also consider the
different strengths of evidence for health risks associated with
carbon monoxide, benzene, and MTBE. Using a common metric to
compare the health effects of each chemical, such as a
margin-of-exposure approach (see section 3.1), would be useful.
The following is an example of the framework in action at the
regional level.
Beginning in 1978, the Association of Bay Area Governments
(ABAG) developed and adopted an integrated, comprehensive
environmental-management plan for the San Francisco Bay region
(ABAG 1978). The plan recommended actions to improve and manage
the region's air-quality, water-quality, water-supply, and
solid-waste problems in an integrated, comprehensive manner. ABAG
was designated as the lead agency by the state of California
under various federal and state laws. The plan was developed to
meet the requirements of the Air Quality Maintenance Plan under
the Federal Clean Air Act Amendments of 1977, of the areawide
plan under the Federal Water Pollution Control Act Amendments of
1972, of the Federal Resource Conservation and Recovery Act of
1976, of the California Solid Waste Management and Resource
Recovery Act of 1972, and of California Senate Bill 424 of 1977.
• Collaboration. The plan was developed
through an extensive collaborative process that involved a broad
range of stakeholders, including representatives of federal,
state, and local regulatory agencies, business, labor,
environmental groups, ethnic minorities, and city and county
governments. A 46-member environmental-management task force
charged with plan preparation was formed by ABAG with the
stakeholders well represented. The task force was chaired by
Dianne Feinstein, then mayor of San Francisco. Community outreach
was extensive, and several hundred roundtables, meetings, and
formal public hearings were held.
• Problem/Context. Stakeholders were
involved at the beginning of management-plan development to
identify environmental problems in the region. For example,
photochemical oxidants in the air, toxic materials in the San
Francisco Bay, and inadequate solid-waste disposal practices were
identified as some of the important problems. Potential
relationships among the problems were also identified so that
they could be considered in a multimedia, integrated manner. For
example, solid-waste disposal sites could cause surface-water and
groundwater contamination and could produce dust, gases, and
odors that affected air quality. Therefore, properly managed
landfills were considered to be control measures for air and
water pollution, as well as for solid-waste disposal problems.
• Risks. Risk information was compiled and
communicated to the stakeholders. For example, health effects of
photochemical oxidants and harmful effects of toxic materials on
aquatic life were described to the stakeholders at various
meetings. However, risk assessment was not performed extensively,
because control measures were chosen on the basis of federal and
state requirements.
• Options. Options for control measures
were developed with extensive input from stakeholders. The most
controversial measure was land-use controls for maintenance of
air quality after 1985. The proposed control measures were
evaluated for their environmental benefits, consequences, and
costs and for their probable social and economic effects on the
region.
• Decisions. Control measures were selected
by the environmental-management task force, which was composed of
locally elected officials and other stakeholders. Many of the
control measures were voted on and adopted by the task force.
However, after many months of discussion and the expression of
substantial concern by labor, business, and many of the cities
and counties in the region, the land-use control measure for
maintenance of air quality was eliminated from the plan. In the
decision-making process, several important issues were raised,
including federal-state-local relationships, the social and
economic impact of land-use controls, the extent of air-quality
improvement likely to be obtained, and the suitability of
including these measures in an air-quality plan.
• Actions. Because so much care that was
taken to analyze problems and solutions and to make decisions
with broad stakeholder participation, many of the actions
recommended by the plan were taken by public agencies,
businesses, industries, and private citizens. The plan continues
to serve as a blueprint for environmental-management activities
in the bay region. For example, a state implementation plan for
air quality was developed in response to the plan and, as a
result, the region was designated as an attainment area for ozone
under the federal Clean Air Act in 1995. Almost all the
industrial and municipal wastewater-treatment facilities have
been upgraded. Erosion-control measures to reduce nonpoint-source
pollution have been in place for many years. A council of
water-supply agencies has been formed and has engaged in
cooperative efforts, such as the development of a
drought-response strategy for the region. Hazardous-material
spill response teams have become available at the city and county
levels. ABAG also provided technical assistance to local agencies
to initiate recycling programs.
• Iteration. The plan recommended
procedures for continual adjustment as new information or new
technologies became available. Iteration was, in fact, carried
out over the years.
• Evaluation. As a result of this
collaborative, integrated environmental planning effort, the San
Francisco Bay region has enjoyed substantial environmental
improvement over the last 15 years. Although ABAG's designation
as lead agency has expired, a planning process was continued by
state and local agencies. Although no formal evaluation of the
plan has been performed, much of the environmental improvement in
the region can be attributed to implementation of the plan. The
San Francisco Bay region is now considered by many to be one of
the environmentally best managed metropolitan areas in the
country, as a result of the comprehensive, integrated,
collaborative environmental-management effort started almost 20
years ago.
Local and Community Levels. A city or a community can
use the framework to address risks to its citizens. For example,
radioactive-waste cleanup is a community-level, multimedia
problem and should include effective local stakeholder
involvement. When DOE began to address the cleanup problem at
Hanford, the surrounding community was not adequately informed or
involved, and that led to outrage and distrust. Involvement of
the community as partners in risk management at the site since
then has led to improved cooperation and more readily accepted
decisions.
Other uses of the framework at the local level include the
development and operation of industrial facilities or
waste-disposal facilities.
Our risk-management framework constitutes a major shift in the
emphasis that risk assessment plays in risk-management
decision-making and has three critical advantages. First, it is
consistent with using an integrated, holistic, top-down approach
to a public-health or environmental problem instead of a
chemical-by-chemical, medium-by-medium, bottom-up approach to
characterizing individual risks; decisions about how to use risk
assessment, and how extensively, are made from the perspective of
risk management. Second, it emphasizes collaboration,
communication, and negotiation in an open and inclusive process
among stakeholders so that public values can influence the
shaping of risk-management strategies; the results are intended
to be decisions that are more pragmatic and more easily
implemented than those made in the absence of consensus and
solutions that incorporate the diversity of interests, knowledge,
and technical expertise represented among stakeholders. Third,
like the scientific process, the proposed risk-management process
is iterative; at any stage of the process, the discovery of new
information can change conclusions and decisions and lead to
reformulation and re-evaluation of the problem at hand.
The Commission emphasizes that the proposed framework will
need to be refined with experience. As illustrated by the
examples described above, some elements of the framework, such as
stakeholder involvement and multimedia analysis, have been tried.
However, no risk-management effort to date has used all aspects
of the framework. Many of the questions and concerns associated
with this framework will be clarified as it is more widely used.
We recommend that evaluation be an integral component of the
process.