Defining Problems and
Putting Them in Context

The problem/context stage is the most important step in the Risk Management Framework. It involves:

  1. Identifying and characterizing an environmental health problem, or a potential problem, caused by chemicals or other hazardous agents or situations.
  2. Putting the problem into its public health and ecological context.
  3. Determining risk management goals.
  4. Identifying risk managers with the authority or responsibility to take the necessary actions.
  5. Implementing a process for engaging stakeholders.

These steps are all important, but may be conducted in different orders, depending on the particular situation. For example, when a state or federal regulatory agency is mandated to take the lead on a problem, the steps often will proceed in the order listed above, with the identity of the risk managers already clear, since the state or federal agency will have assumed that role from the start. On the other hand, if the group or individual discovering the problem is not in a position to be the risk manager or to characterize the problem, stakeholders might have to engage in a collaborative stakeholder process to identify risk managers with the needed authority before the other steps can take place. Each step in the problem/context stage of the risk management process is described below.

1. Identify and Characterize the Problem

An environmental or human health problem may already be well recognized or may be a potential problem. Ideally, potential problems will be anticipated and addressed at a very early stage. Problems may be identified through a range of indicators, using such methods and events as:

A good risk management decision addresses a clearly articulated problem in its public health and ecological context.

Potential problems may take some searching to identify.

 

Characterizing a problem involves investigating what is causing the problem and who or what is affected. For example, characterizing an environmental problem could involve identifying which pollutants or other stressors (such as sediment in a stream) are causing the problem, determining the sources of the pollutants or other stressors, and then determining which human and/or ecological populations are affected. While problem identification may be performed by an individual stakeholder (including the risk management authority), problem characterization should be performed in collaboration with other stakeholders. Here are some questions to ask when characterizing a problem:

Hazard

Exposure

Problem characterization may be iterative, requiring several attempts at refinement as new information is gathered. For example, stakeholders joining the process may bring important information or insights that could modify a characterization or suggest additional lines of investigation. Early iterations might focus on research and education, while later iterations focus on specific pollution reduction measures.

How the problem is characterized will have a tremendous impact on the focus and likely outcome of the risk management process. For example, a problem related to waste disposal capacity could be characterized:

Children can experience higher
exposures to pesticides than adults
because they eat larger amounts of fruits
and vegetables for their size.

 

If a problem is characterized too narrowly or incorrectly, risk managers and other stakeholders will invest their resources in exploring and implementing solutions that will be inadequate, less effective, or more costly for reducing risk than they might have been. Also, inappropriate solutions can produce unintended consequences. For example, tightening solid waste disposal regulations can lead to an increase in illegal dumping. In the case of Superfund site cleanups, Resource Conservation and Recovery Act regulations have engendered disposal methods that pose even greater risks than the Superfund sites themselves. Therefore, it is very important to consider the full context of the problem, as described below, before proceeding with other stages of the risk management process.

2. Carefully Consider the Context

A full understanding of the context of a risk problem is essential for effectively managing the risk. Yet historically most risk management has occurred in an artificially narrow context that considers just one chemical, one environmental medium, and one risk at a time. Because this narrow context does not reflect the true complexities of risk situations, it results in risk management decisions and actions that are less effective than they could be. The Commission’s Framework expands the context of risk management by including a step in the opening stage, described here, to explicitly consider and define a comprehensive context for a specific risk that is broadly reflective of real-life risk situations. To do this, risk managers and stakeholders must systematically consider several key dimensions of the risk’s context:

Multisource context. Is the population exposed to the same pollutant from other sources? For example, a local community might be concerned about breathing pollutants such as hydrocarbons and particles released to the air from a nearby power plant, but it might also be breathing hydrocarbons and particles from motor vehicle exhaust, wood stoves, secondhand tobacco smoke, or other sources. (See "The Multisource Context: Air Toxics" and "The Multisource Context: Residual Risks from Petroleum Sources" on pages 11 and 12 for elaboration.)

Understanding the context of a risk problem is essential for effectively managing the risk.

 

Multimedia context. Is exposure to the pollutant also occurring from other environmental media? In the power plant example, the community members who are concerned about breathing pollutants could also be exposed to them from food, water, or soil. Other sources of hydrocarbons could be food (such as broiled meats) and soil (resulting from cumulative contamination from decades of emissions from the power plant, vehicles, and other sources). (See "The Multimedia Context: Residual Risks From Secondary Lead Smelters" on page 12 for elaboration.)

The broad context of risks in this community include an
industrial facility, motor vehicles, lead paint, and contaminated soil.

 

Multichemical context. Do other pollutants from the same sources pose additional risks to the population of concern? Do the pollutants interact? Are their effects cumulative? In the power plant example, other air pollutants may pose risks for similar adverse effects or may produce different effects when in combination than they do alone. For example, hydrocarbons are usually attached to very small particles, which can increase the risk of cancer from hydrocarbons alone and which can interact with ozone and other air pollutants to form smog.

Multirisk context. How great a risk does the problem pose compared to other similar risks that the community faces from environmental chemicals? For example, the risks of respiratory disease associated with exposure to power plant emissions might be compared with the risks of diseases associated with exposure to heavy metals from local municipal solid waste incinerator emissions and the risk of neurological disorders resulting from exposure to a local drinking water source that is contaminated with industrial solvents. ("The Multirisk Context: Ecological Degradation" on page 13 provides an ecological example.)

There may be even broader public health or ecological contexts that local governments and public health agencies have to confront and weigh against chemical exposures—for example, a high incidence of HIV or other infections, a low rate of childhood vaccination, a high drug use and crime rate, or a high rate of alcoholism and its contribution to liver disease, birth defects, and injuries from automobile accidents.

In the power plant example, the initial problem is defined as the health risks posed by air pollutants emitted by a particular type of industrial facility in a particular geographic area. The multisource context would involve identifying other sources (e.g., other types of industrial facilities, motor vehicles) that emit those same pollutants to the air in the same geographic area. The multimedia context would involve identifying other environmental media that serve as local pathways of exposure to the same pollutants. The multichemical context would involve comparing the risks from those particular pollutants with the risks associated with other important air pollutants from the same source, such as sulfur oxides and nitrogen oxides. Finally, the multirisk context could consider risks posed by water contamination and solid wastes in the area, and sometimes, other risks to public health.

A problem's context can include other chemicals and other environmental media, and other risks.

 

An initial problem might also be identified and evaluated on the basis of a particular health effect instead of on the basis of contaminant emissions. For example, the increasing incidence and mortality rates of asthma could be addressed. The reasons for the increases are not known, but likely candidates include sulfur oxides, smog, particles, and second-hand tobacco smoke.

The relevant contexts that are identified and characterized after these considerations, and the rationale for their identification, should be incorporated into the risk analysis (see "How Should Risks be Analyzed?" on page 24).

The Multisource Context: Air Toxics

Under the 1990 Clean Air Act, EPA is required to promulgate maximum available control technology (MACT) standards for major sources of hazardous air pollution. MACT standards reduce, but don’t necessarily eliminate, air pollutants from these sources. For this reason, the Clean Air Act requires EPA to assess the residual risk caused by the air emissions that will remain after MACT standards are implemented.

Several types of industrial facilities that emit the hazardous air pollutants benzene, 1,3-butadiene, formaldehyde, and acetaldehyde will require MACT standards. A 1993 EPA study of the risks associated with motor vehicle emissions of these same pollutants provides an important context for evaluating the residual risk from those facilities.

Motor vehicles contribute 60%, 94%, 33%, and 39% of the nationwide total of benzene, 1,3-butadiene, formaldehyde, and acetaldehyde air pollution, respectively. EPA estimated the cancer risk of these pollutants for the years 1990, 2000, and 2010. For the 1990 estimate, EPA assumed that 1990 automotive technology was in place. For the 2000 and 2010 estimates, EPA assumed that a number of controls would be in place, including those required by California’s stringent emissions standards and a requirement that reformulated gasoline be used by vehicles in all areas of the country that do not attain the current national ambient air quality standard for ozone.

Benzene, formaldehyde, and acetaldehyde from motor vehicles were each estimated to cause no more than 30 additional cases of cancer nationwide per year in any of the years evaluated, while 1,3-butadiene was estimated to cause no more than 300. (At present there are more than 500,000 new cases of cancer each year in the United States.)

The fact that air toxics from industries properly controlled under MACT standards are not likely to be the major sources of cancer risk will be an important context for EPA to consider when the residual risks from industries are assessed and compared to risks from other sources of cancer and respiratory disease. This situation reinforces the need to view all air pollution risk management activities in one context. Both EPA and California have started to do just that by developing integrated air toxics strategies.

The Multisource Context: Residual Risks From Petroleum Sources

In July 1994, EPA promulgated a MACT standard for petroleum refinery emissions. That standard was based partly on EPA’s finding that benzene in refinery emissions poses a potential leukemia risk to exposed populations. The standard will reduce, but not eliminate, the benzene and other hazardous air pollutants emitted by petroleum refineries.

Once the standard is implemented, a series of local and regional risk assessments will be conducted to determine whether the remaining benzene in emissions from individual petroleum refineries may pose a leukemia risk in their local area. At this stage it will be important to consider other sources of benzene in air. In fact, motor vehicle emissions are the largest single source of airborne benzene in the United States. When assessing the residual risk from benzene in refinery emissions in a particular region, the benzene risk from refinery emissions could be compared with the benzene risk from mobile sources and any other important benzene emission sources in the area—including benzene in cigarette smoke and from consumer products used at home. It would be appropriate for stakeholders to identify who has responsibility for controlling the other sources.

If the residual leukemia risk from refinery emissions is significant compared to the leukemia risk contributed by other sources, risk-reduction efforts should focus on further reducing refinery emissions. However, if the refinery risk proves insignificant, risk reduction might better be directed at other sources. The overall goal should be to direct risk management resources where they will do the most good to protect or improve the community’s health.

A situation in which the multisource context was ignored, with unfortunate results, arose in New Jersey. Benzene is a contaminant found in the air and sometimes the groundwater near marine oil terminals. Benzene levels were measured inside homes near a marine oil terminal and, because the levels were believed to be unsafe, residents were evacuated. In fact, the benzene levels were well within the range found in homes nowhere near any external source, but residents have refused to return to their homes, property values have decreased substantially, and a great deal of community discord persists.

The Multimedia Context: Residual Risks from Secondary Lead Smelters

EPA promulgated MACT standards for secondary lead smelters to reduce human exposure to arsenic, lead, and other pollutants in smelter emissions. Assessing residual risk was difficult because few site-specific data were available on exposure to smelter emissions. To compensate for this data gap, EPA performed a screening risk assessment that relied on many assumptions.

Arsenic. Arsenic causes skin disorders and can increase lung cancer risk. EPA’s screening assessment indicated that residual arsenic emissions 100 meters from a smelter would be about one hundred times the average air concentration of arsenic in the United States and about one thousand times the maximum exposure level that EPA considers to pose negligible risk. An examination of other major sources of arsenic exposure (principally seafood consumption and smoking), however, indicates that smelter emissions actually account for only one-tenth of exposure to arsenic for people living 100 meters from the smelter. Thus, the total exposure context raises a broader risk management issue about what actions should be taken to reduce exposure from all sources. The first step should be to measure actual arsenic concentrations in air around the smelter to compare more accurately the contributions of all sources of arsenic.

Lead. Exposure to lead can cause brain damage. Children are particularly vulnerable. EPA’s screening risk assessment found that exposure to lead emissions 100 meters from a secondary lead smelter would be about ten times greater than both the national ambient air quality standard for lead and the average concentration of lead in the United States. Although there are many other sources of human exposure to lead, an analysis of total exposure around the smelter shows that the smelter itself is by far the primary contributor. Thus, in the case of lead the total exposure context confirms that smelters should be the leading target for risk reduction in those communities. Monitoring children’s blood lead levels would be a good first step to help guide risk management actions and to evaluate their results.

The Multirisk Context: Ecological Degradation

Many problems not only have multiple sources (the multisource and multimedia contexts), but also are interdependent with other problems (the multirisk context). For example, degradation of watersheds typically is caused by a variety of sources that may include specific industrial discharges, urban and agricultural runoff, land-disturbance activities such as logging and grazing, diversion of water for domestic and agricultural use, overfishing, the introduction of exotic species, and deposition of air pollutants into water. In such cases, risk managers must consider these problems in multisource and multirisk contexts in order to develop effective solutions.

One example of a problem requiring multirisk analyses and multisource solutions is the decline of salmon populations in the Columbia River Basin. According to Pacific Fisherman Yearbooks, the annual salmon and steelhead catch ranged between 25 and 44 million pounds of fish in the early 1900s. By the 1940s, the range had declined to between 13 and 30 million pounds due to overfishing, irrigation, and power dams. Since that time, many believe that the salmon fisheries have been further stressed by nuclear reactors that have contributed radiation, heat, and chemicals to the Hanford Reach of the Columbia River and by population increases that have resulted in pollution from sewage treatment plants, industrial discharges, and runoff. In the tributaries, timber harvesting has increased sedimentation, water temperature, and blockages of important spawning habitats. Salmon populations have continued to decline.

The ecological consequences of this degradation are accompanied by other impacts. For example, the decline in the salmon fisheries has affected the diet, culture, and religious practices of the Yakama Indian Nation. To successfully address the Columbia River’s degradation, risk managers will need to consider multiple sources of stress and complex risk management strategies.

Risk management goals should be used to guide risk analyses.

 

3. Identify Risk Management Goals

The goals of risk management are varied. They may be risk related, aiming to:

They may be economic, aiming to:

They may involve public values, aiming to:

They may also be dictated by statute, policy, or existing regulations.

Risk management goals should be used to guide the next stage of the Framework—Analyzing Risks—but the results of risk analysis may lead stakeholders and decision-makers to redefine those goals. It is important to identify the goals early, so they may serve to guide the rest of the decision-making process.

4. Identify Risk Managers

The risk manager is the person responsible for managing the problem. Who the most appropriate risk managers are in a particular situation will depend on the problem’s context. In some situations, such as a regulatory context, it will be obvious to all stakeholders that the responsible regulatory agency should or must manage the problem. In other cases, it may not be obvious, or different stakeholders may have different opinions. If so, the issue of who should be the risk manager or managers must be resolved at this stage of the risk management process. Often, risk management responsibilities can be shared, or evolve with changing circumstances. Sometimes, who the risk manager should be will not become evident until the risk management options are identified.

Many different types of people may be risk managers, including:

Federal regulators Plant managers
State regulators Public health officials
Local regulators Clinicians
Local businesses Citizens
Industries  


Stakeholders are more likely to accept and
implement a risk management decision they
have helped to shape.

 

5. Establish a Process for Engaging Stakeholders

The appropriate numbers and types of stakeholders depend on the situation.

A stakeholder is anyone who has a "stake" in a risk management situation. Stakeholders typically include groups that are affected or potentially affected by the risk, the risk managers, and groups that will be affected by any efforts to manage the source of the risk. The overlap between "Engage Stakeholders" and "Problem/Context" in the Framework hexagon on page 3 is larger and darker than the other overlaps because active stakeholder involvement at this particular stage is the most critical element of the decision-making process.

Who the stakeholders are depends entirely on the situation:

Questions that can help identify potential stakeholders include:

Thus, stakeholders may include:

Why Is Stakeholder Involvement Important?

Experience increasingly shows that risk management decisions that are made in collaboration with stakeholders are more effective and more durable. Stakeholders bring to the table important information, knowledge, expertise, and insights for crafting workable solutions. Stakeholders are more likely to accept and implement a risk management decision they have participated in shaping. According to a 1996 public opinion poll, 80% of U.S. citizens think that the responsibility for controlling risks should be shared by government, businesses, communities, and individuals and that government at all levels should involve citizens in health and environmental protection.

Stakeholder collaboration is particularly important for risk management because there are many conflicting interpretations about the nature and significance of risks. Collaboration provides opportunities to bridge gaps in understanding, language, values, and perceptions. It facilitates an exchange of information and ideas that is essential for enabling all parties to make informed decisions about reducing risks. Collaboration does not require consensus, but it does require that all parties listen to, consider, and respect each other’s opinions, ideas, and contributions.

The Commission acknowledges concerns that the costs and additional time needed to involve stakeholders in risk management can be considerable. However, risk management by government agencies has generally been costly anyway, and investment in stakeholder involvement can bring long-term savings, especially when stakeholder involvement catalyzes win-win solutions or when litigation becomes less likely or less protracted. The U.S. Department of Energy, the U.S. Department of Defense, and several states have reported that including community stakeholders in their decision-making process for cleaning up contaminated sites substantially reduced the overall time and expense required.

(See "Seven Benefits of Engaging Stakeholders.")

How Can Stakeholders Be Engaged?

The Risk Management Framework promotes at least some stakeholder participation at each stage of the risk management process. Every risk management situation has a spectrum of interested and affected parties who have different perspectives, concerns, knowledge, and interests. Some parties are proactive in seeking involvement. Others are not. In all cases, however, risk managers should work to:

Incentives for stakeholders to become involved might be helpful in some cases. For example, some community stakeholders have received child care and transportation expenses or funding for technical reviews. Some industry stakeholders could be attracted by the potential for reduced reporting requirements or more efficient permitting. Sometimes, industry stakeholders cover the expenses of community stakeholders through mechanisms such as community advisory groups.

Not all risk management decisions will benefit from extensive stakeholder collaboration. The nature and complexity of stakeholder involvement should be consistent with the:

There are no hard-and-fast rules for stakeholder involvement. Research on stakeholder involvement is in its early stages, so we are still learning what works, what doesn’t work, and why. Nonetheless, a number of guidelines were developed on the basis of the experiences to date that practitioners shared with the Commission, which seem basic to effective stakeholder involvement. Those guidelines are described in the box on page 16 ("Guidelines for Stakeholder Involvement").

Successfully Engaging Stakeholders: San Francisco Bay/Delta Accord

Declaring "a major victory of consensus over confrontation" on December 14, 1994, California Governor Pete Wilson and Cabinet-level federal officials announced the signing of an historic agreement to protect the San Francisco Bay/Delta estuary—the largest and most productive estuary on the West Coast. Known as the Bay/Delta Accord, the agreement was negotiated by the leadership of the state’s environmental, urban, and agricultural interests. The accord broke decades of gridlock on California water policy issues by establishing an integrated, ecosystem based approach to protecting the estuary while providing more reliable supplies to the state’s urban and agricultural water users.

The collaborative process that led to the accord marked a sharp departure from the decision-making approach traditionally used under the Clean Water Act and Endangered Species Act. Rather than issuing proposals developed by individual agency experts for formal public comment and review, the agencies worked together with environmental, urban, and agricultural interests over two years to identify common goals and mutually acceptable solutions. The final standards were developed through an extensive peer-review process that involved both local and national experts in estuarine systems. This approach sharply reduced the number of legal and scientific challenges that accompany most major agency decisions, and has been hailed as a national model for solving environmental problems.

Building on the success of this collaborative process, the state and federal agencies and interest groups have continued to work together as part of the new CALFED Bay/Delta Program to develop long-term ecosystem restoration goals. In 1996, the agencies and interest groups reached consensus on a $995 million bond measure that will help finance the ecosystem restoration process and other projects vital to the program’s success. The bond was passed by voters in November 1996.

Insufficient Stakeholder Collaboration: Granite City, Illinois

When stakeholders are not included early in the decision-making process, they are more likely to oppose the risk management decision and block its implementation. This has been happening in Granite City, Illinois, since 1993, according to testimony from Mayor Ronald Selph and Alderman Craig Tarpoff. Heavily contaminated with lead by a former smelter, much of the city was designated by EPA as a Superfund site. Based on soil sample analyses and a screening risk assessment model, EPA decided to remove the contaminated soil around 1,200 homes and businesses and haul it away.

Some believe that EPA made this decision without adequately consulting the community. City officials believe that this remedy ignored a number of problems:

The industrial facility held responsible for the contamination did not respond to EPA’s decision, so the agency sued the facility. The city then filed a petition in the suit because officials felt that neither EPA nor the responsible party represented the best interests of the community. EPA began the cleanup anyway, but was restrained by court order. EPA retained an expert whose analysis supported the agency’s choice of remedy and the city retained an expert whose analysis concluded that removing contaminated soil would be fruitless unless the remaining sources of contamination—house paint, the smelter waste pile, and the trucking lot soil—were removed as well. Granite City residents are left confused and caught in the middle—some support the city and some support EPA. Property values have fallen. As of late 1996, the case remains unresolved and is back in federal courts.

(See also "Involving Stakeholders in Maine" and "The Important and Synergistic Roles of Regulatory and Public Health Agencies in Identifying and Reducing Environmental Health Risks.")

 

Local public health agencies can play an important role in the execution of the Commission’s Risk Management Framework. In Boston, the Department of Public Health produces neighborhood health reports, which individually describe the health status of 16 neighborhoods. The department asked residents what they thought their priorities were, then set up forums for discussing those priorities and pursuing ways to achieve public health goals. Each year the department updates and expands the reports based on neighborhood needs and priorities.

—Ngozi Oleru, Director,
Office of Environmental Health,
Boston Public Health Commission