Priority-setting is necessary when money, time, and staff are limited. The Carnegie Commission on Science, Technology, and Government, the National Academy of Public Administration, many members of Congress, and Supreme Court Justice Stephen Breyer have recommended comparative risk-assessment approaches for priority-setting.⁽¹⁾ The comparative-risk process includes a variety of tasks, from problem identification, data collection and analysis, and risk ranking of environmental problems to developing an action plan and implementing new strategies for risk management and reducing risk. Most of the comparative-risk projects for priority-setting have been initiated by state, local and tribal governments and typically by one or more of the environmental protection, natural-resource, or health agencies. Our recommendation here is directed at federal agencies.

FINDING: Federal regulatory agencies are confronted with many problems and issues related to health and environmental protection, but have limited time and resources for action. The risks associated with the problems and the resources available to act on them are often misaligned. State, local, and tribal comparative-risk projects have been useful in addressing such mismatches and in refining the comparative risk process to better manage risks.

RECOMMENDATION: Agencies should use a comparative-risk assessment approach for risk- management on an experimental or demonstration basis to test the effectiveness of seeking consensus on setting priorities for environment, health, and safety hazards. The priorities, reflecting diverse stakeholder values and opinions, should influence agency resource-allocation decisions.

RATIONALE

The Environmental Protection Agency (EPA) undertook some of the earliest efforts to use comparative risk assessment to rank environmental risks and set priorities for agency efforts. In 1987, EPA staff prepared a report, Unfinished Business: A Comparative Assessment of Environmental Problems (U.S. EPA 1987b), that identified risks receiving in their view inadequate attention from the agency. An important conclusion of the report was that the EPA's program priorities tended to reflect the public's perception of risks, rather than the most serious risks as judged by EPA scientists and staff. The Science Advisory Board reviewed that report and issued Reducing Risk: Setting Priorities and Strategies for Environmental Protection (SAB 1990). The Science Advisory Board emphasized the subjective nature of rankings and called for broad public participation in ranking environmental risks so that risk reduction policies based on imperfect and evolving scientific understanding and subjective public opinion would be supported widely. In 1995, EPA and Congress asked the Science Advisory Board to undertake an integrated ranking project as a follow up to the risk rankings in Reducing Risk. The difference in those efforts and the EPA-funded state, local, and tribal comparative-risk projects is the explicit incorporation of public values and perceptions of risk, a process of diverse stakeholder involvement, and inclusion of elected-officials' representatives in the state, local, and tribal activities. As a result, it appears that the state, local, and tribal comparative risk assessment projects might have been more successful in influencing agency priorities and resource allocations. Unfortunately, Congressional proposals to institute comparative risk assessment reports by federal agencies along with appropriate adjustments in budget requests have not reflected the experience and enhanced understanding of the role of public values in priority-setting gained from the state, local, and tribal comparative risk assessment for risk management projects.

Comparative risk assessment for priority-setting brings together science and public values by making clear what is known and what is not known about the environmental challenges we face. The comparative-risk process includes organizing teams of agency and nonagency stakeholders, such as representatives of business and environmental groups; making a comprehensive list of environmental problems; assembling the available good information about the sources of the problems and the risks that they pose to human health, ecosystems, and quality of life; ranking the problems in order of the group's view of the risks posed; and using the rankings to guide strategic planning and budgeting. Methods for ranking the risks of identified problems have included: voting by participants, formulas that rely more heavily on quantitative data, matrix-based discussions that use graphics in a shared decision-making process, decision-seeking consensus, and bargaining or tradeoffs among stakeholders. That approach to comparative risk assessment for risk management tracks the six steps of the Commission's risk-management framework (see section 2) and can mobilize and energize stakeholder participation.

Each federal agency will need to adapt the fundamental elements of the comparative-risk ranking approach to its mission, statutory mandates, and current and emerging responsibilities. At the federal level, agencies can substitute Congressional staff of authorizing committees of Congress for state and local representatives and can identify as participants internal agency and affected stakeholders on the basis of programs and projects of specific agencies. Depending on the agency, it will be important to include representatives from state, local, and other federal agencies with relevant programmatic responsibilities or interests. State and local participation will be especially important as roles and obligations change under the Unfunded Mandates Act of 1995, which places limits on the capacity of the federal government to implement new programs that will cost state and local governments over $50 million in any year.

Benefits other than priority-setting often justify putting time and effort into the comparative-risk assessment process for priority-setting (Minard and Jones 1993). Most comparative-risk projects produce a catalog of the major environmental problems facing a state or locality, which can be a valuable resource for the public and for risk managers. Participants in a comparative-risk project learn about a range of problems that might not be part of their daily interests or responsibilities. The comparative-risk process improves understanding of competing priorities, provides an appreciation of the complexity of decision-making, and can stimulate new insights into solutions. As a result of increased communication among institutions and interest groups, new avenues of cooperation might be established. Adversarial relationships among interest groups and jurisdictional conflicts among agencies might not disappear, and could even be intensified, but comparative-risk projects have revealed unexpected agreement among parties and enhanced understanding of differences in perspectives and values in some cases. Most important, experience has shown that the process itself can help to build coalitions that favor priority setting and shifting resources to the identified priorities. Broader public support for a common agenda might allow agencies, state legislatures, and Congress to move money and staff into priority problems with less litigation and less controversy. In fact, Charles Kleeburg, director of the Seattle Drainage and Wastewater Utility, explained to the Commission that the city's success in forging consensus on 10 priority problems that were acted on by the city government was a direct result of the influence and effectiveness of the comparative risk assessment process. In contrast, testimony from EPA indicated that a great deal of controversy is generated when it tries to address problems that it knows are real, but has not been told by Congress to address.

There are a number of challenges to and limitations to the usefulness of the process as pointed out by Patricia Buffler and Carl Craner, in their testimony before the Commission about the California Comparative Risk Project. For example, there is no guarantee that the process will produce consensus among stakeholders, agencies, and funding authorities. Resolving inconsistent data across problems, forcing all risks into a common measurement, and integrating problems into a single list are important methodologic challenges. The degree of uncertainty varies across problems, making comparisons difficult. The process might not adequately account for environmental equity, emerging issues, and effects across jurisdictional boundaries. Those problems can result in some groups' objecting strongly to the rankings, in loss of opportunities for preventing future risks, and in the neglect of risks imported from or exported to other geographic areas. Lack of sufficient resources and time constraints can limit data collection, diminish the quality of data analysis, and hinder development of risk-management strategies and recommendations. For federal agencies, there may be additional problems of having to propose changes to statutory mandates when priorities for resources change and the difficulty in taking action in the absence of clear or explicit statutory direction.

The comparative-risk process emerging from the state, local, and tribal projects supported by EPA constitutes a worthy starting point for federal agencies to use in ranking priorities and making resource-allocation decisions. For example, the risk-based process being introduced by the Department of Energy's Environmental Management Program at the nation's nuclear-waste sites is testing how well identification, analysis, and comparison of risks and remedies can be translated into budget decisions. The Commission encourages federal regulatory agencies to use comparative risk for priority-setting on an experimental or demonstration basis.

¹ Section 5.1 of this report considers comparisons of specific risks for the purpose of communicating about risk.