A Proposal by
The Commission on Risk Assessment and Risk Management
for a
Symposium on Defining a Public Health
Approach to Environmental Protection
Background1
There is a compelling public health and ecological case to be made for modernizing our approach to environmental regulation. To a considerable extent, we are "fighting the last war" on the environment, using prescriptive, media-specific laws and bulky, centralized institutions designed in the 1970s to pay the debt on the post-World War II industrial boom. Problems, needs, and knowledge have changed dramatically over the last twenty five years. Through the fragmentary and narrowly focused corpus of existing environmental law, we implicitly make choices about where to direct public and private resources. In academic circles, the question is often asked whether these choices are still valid. However, a politician asking this same question does so with peril. The question implies that instead of the clearly delineated requirements of an existing statute, policy would be driven instead by overarching objectives of public health or ecology. Priorities would naturally be shifted, and not all current statutory requirements pursued with comparable vigor. Similarly, answering the question could easily lead to the view that standards set using a single objective of public health protection or resource protection should be treated instead as aspirational goals, instead of absolute limits, and traded off among themselves in pursuit of a socially optimal investment strategy. These are critical choices that deserve to be fully aired in public debate.
Equally important, we need creative and constructive thinking about governance tools that would allow trade-off processes to proceed in a fair and open manner with some assurance that resources can indeed be shifted to higher priorities within the environmental and public health "system." For example, instead of huge investments in lowering emissions by an amount that may have a marginal impact on public health, a facility in compliance with current air quality standards could propose to invest instead in asthma research and treatment. The goal is to focus our environmental protection resources where they may have the greatest impact on public health while continuing to address other public objectives.
Goals and Objectives
We propose to hold a one-day symposium with Commission members and invited participants to address issues related to the Commission's recommendation that we move towards a public health approach to setting priorities for environmental protection. Such issues include:
The symposium would also explore the idea of an "environmental health improvement market," in which, abiding by both "polluter pays" and efficiency principles, a facility already in compliance with current standards would be offered the chance to invest not in marginal decreases of emissions but in more worthwhile projects to improve public health. The example of the recently proposed revisions to the National Ambient Air Quality Standards for particulates and ozone would be examined as an opportunity, in some narrowly defined circumstances, for such market trade-offs.
The symposium would build on Volume 1 of the Commission's final report and on the work of Debra Knopman at the Progressive Foundation's Center for Innovation and the Environment. The outcome of the symposium would be a set of recommendations designed to help move us toward implementation of the Commission's approach to risk management.
1From Debra Knopman’s submission to the Society for Risk Analysis.
Related Links
Proposed Schedule for the Commission’s Symposium on Defining a Public Health Approach to Environmental Protection
RiskWorld News Article Titled "Risk Commission To Hold Symposium Defining a Public Health Approach to Environmental Protection"
Home Page of the The Commission on Risk Assessment and Risk Management
Last updated on July 24, 1997.