Making a Decision

Who Decides?

During this stage of the Framework, decision-makers review the information gathered during the analyses of risks and options to select the most appropriate solution. When the risk problem falls under the purview of a federal, state, or local regulatory authority, the regulatory agency makes the risk management decision. Consumers, manufacturers, and others responsible for wastes and pollution also can make socially important decisions to reduce or eliminate risks. A productive stakeholder involvement process can generate important guidance for decision-makers. Thus, decisions may reflect negotiation and compromise, so long as statutory requirements and intent are met. In some cases, win-win solutions are available that allow stakeholders with divergent views to achieve their primary goals.

Involving stakeholders and incorporating their recommendations where possible reorients the decision-making process from one dominated by regulators to one that includes those who must live with the consequences of the decision. This not only fosters successful implementation, but can promote greater trust in government institutions. (See also, "A good risk managment decision reduces or eliminates risks in ways that... .")

What Is the Best Decision?

In most risk management situations, decision-makers will have a number of options from which to choose. Which option is optimal depends on the particular situation. Seven criteria, listed above and discussed below, are fundamental characteristics of any sound risk management decision. These criteria echo the key themes that underlie the early stages of the Framework because the goal of the earlier stages is to produce the most relevant and useful information for sound risk management decision-making.

Usually, the technical information that is available on which to base a risk management decision is incomplete. Decision-makers often must rely on:

Because so many judgments must be made based on limited information, it is critical that all reliable information be considered. Risk assessors and economists are responsible for providing decision-makers with the best technical information available or reasonably attainable, including evaluations of the weight of the evidence that supports different assumptions and conclusions.

Considering a risk in isolation cannot provide decision-makers or the public with any sense of how important the risk is, compared with other risks, or of the impact that reducing or eliminating it might have on overall human and ecosystem health. Considering risks in context can help direct resources toward the risk management actions that will do the most good. As described in the "Problem/Context" section earlier in this report, we need to move away from our current one chemical/one environmental medium/one risk approach toward developing a more comprehensive and holistic appreciation for problems and their contexts, so that meaningful, practicable goals can be developed.

Many risk management options may be infeasible for social, political, cultural, legal, or economic reasons (see the "Examining Options" section of this report), or because they do not reduce risks to the extent needed. For example, groundwater remediation using pump-and-treat technology may be infeasible because, for a variety of technical and hydrogeologic reasons, it will not sufficiently reduce contaminant concentrations in the ground water. Removing all the soil from an entire valley that is heavily contaminated with mining waste is infeasible. Expecting everyone to stop driving automobiles is infeasible. On the other hand, the costs of reducing acid rain by controlling power plant emissions are considered justified by their benefits—protecting streams and lakes and reducing damage to automobile finishes and construction materials. Of course, the feasibility and cost-effectiveness of an option may change in the future as technology is improved or as society’s values change.

If pollutants are not released into the environment, exposure cannot occur. If exposure does not and will not occur, risks will not result. Where feasible, preventing contaminant releases is preferable to removing them or cleaning them up later. Preventing releases can avoid the costs of remediation and health care. Many industries have found that eliminating pollutants can substantially reduce the cost of producing a product.

Command-and-control risk management strategies have significantly improved human health and environmental protection. Alternative strategies will enable even greater levels of protection by encouraging industries, municipalities, and other stakeholders to tailor remedies to reflect the circumstances of individual sources and locations. Encouraging flexibility can result in risk management options that meet or exceed expectations and that are cost-effective. Various alternatives to command-and-control strategies are described in the "Examining Options" section of this report.

The least costly risk management option is not always the most desirable. An option is more likely to be implemented successfully if it takes into account important cultural needs or social impacts (see the discussion of stakeholder involvement in the "Problem/Context" section of this report).

Command-and-control risk management strategies that specify technology that must be used or actions that must be taken can fail to stimulate better, cleaner, and more cost-effective approaches. Without evaluation, the success (or failure) of a risk management action and its unintended consequences may not be determined (see the "Evaluating Results" section of this report). Incentives for research are needed to generate knowledge about hazards, exposures, options, and actions.

"The department has learned the power of having the public involved in decision-making. For example, the citizens advisory board at Fernald has dramatically changed the department’s cleanup strategy at that Ohio site. The results will be a far more expeditious cleanup, with a savings of some $2 billion compared with the cost of the department’s original plans. By opening the process to meaningful public input, the department is empowered to make decisions it could never make unilaterally."

—Carol Henry,
Associate Deputy Assistant Secretary
for Science and Risk Policy,
U.S. Department of Energy

What Happens If There Isn’t Enough Information To Make a Decision?

Decision-makers must balance the value of obtaining additional information against the need for a decision, however uncertain. Sometimes a decision must be made under the precautionary principle. Every effort should be made to avoid "paralysis by analysis" where the need for additional information is used as an excuse to avoid or postpone decision-making. When sufficient information is available to make a risk management decision or when additional information or analysis would not contribute significantly to the quality of the decision, the decision should not be postponed. "Value-of-information" techniques can be used to provide perspective on the next steps to be taken. (See also, "Making Decisions: Steel Industry.")