6. Comparative Risk Analysis for Priority Setting

David B. McCallum and Susan Santos
Focus Group Inc.
Tilghman, MD 21671


Risk-based priority-setting has been accepted by many as the preferred strategy for deciding how to deal with resource-allocation issues. Supreme Court Justice Stephen Breyer, in a book before his appointment, analyzed the cost per death averted for various regulations and concluded that "the entire nation could buy more protection by refocussing regulatory efforts." The Carnegie Commission on Science, Technology, and Government encouraged greater use of comparative risk assessment (CRA). The National Academy of Public Administration, in reviewing Environmental Protection Agency (EPA) practices, suggested that risk-based priority-setting should be increased. Congress has mandated that comparative risk be used in determining which problems to address first.

CRA has evolved, and so has its definition. EPA defines it in a Guidebook to Comparing Risk and Setting Environmental Priorities ( September 1993) as both an analytical process and a set of methods used to systematically measure, compare, and rank environmental problems. It provides a common basis for evaluating net benefits and costs of different strategies for reducing or preventing ... risks ... Rankings can provide an important input to the priority-setting and budget processes when possible risk reduction and prevention strategies are considered in the context of other relevant non-risk concerns, such as economic viability, technological feasibility, and social equity.

CRA projects at the state level have involved hundreds of people from the public and private sectors. Typically, CRA projects at the state level have been carried out by several committees working in concert. These usually include a management committee (often from state or local government), a technical work group (scientists and researchers from the academic and activist communities and potentially industry), and a public advisory committee (representing interest groups). CRA is based on the analytic principles and approaches of rational public-policy analysis dating from the early 1970s. However, CRA has not been neatly, firmly, and finally established. The strength of the comparative-risk process is its ability to "frame" public-policy questions consistently and to engage people productively in addressing them. Its weakness is that the answers can be uncertain, unwelcome, or both. The ultimate goal for government officials, the CRA community, and the public, in using CRA as a tool for environmental planning and protection, is to synthesize the power of the scientific method with the insight of democratic participation.

There is still a high level of experimentation with the process. Indeed, too much standardization at this point could lead to the application of poorer methods. Also, CRA and goal-setting have not been institutionalized in federal or state agencies.


The following actions are recommended:

  • Implement CRA for priority-setting in stages so that it does not overwhelm the human and technical resources.

  • Keep CRA process flexible so that innovations can occur and priorities are not distorted by flawed rankings.

  • Encourage innovation in CRA at the federal, state, and local levels and allocate resources for evaluation of process and outcome.

  • Provide resources to train competent professionals to perform CRA.
  • Legislative

    The role of comparative and traditional risk assessment, cost-benefit-analysis, and risk communication in shaping priorities has been the focus of congressional debate. These tools can provide insight into the effectiveness of regulatory and nonregulatory approaches to health and environmental protection, but they do not yield prescriptive guidance for decision-makers and can be resource-intensive and contentious among stakeholders. Resources must be provided to train professionals in these activities and to allow government, scientific, and public organizations to adequately carry out the analytic and stakeholder participation processes.

    Legislation should set high thresholds for requiring complex analyses; doing a good job on a few assessments is important as the agencies build capacity to do more. It should also recognize the role of expert opinion and should give the risk manager discretion. The comparisons and tradeoffs are complex, and the uncertainty is often high. Allowing discretion and providing active oversight can be more effective than prescriptive guidance.

    Federal Executive Branch

    The Office of Science and Technology Policy and the Office of Management and Budget can identify opportunities for collaboration among agencies and encourage the development and transfer of expertise across the executive agencies. The main thrust must be at the agency level, where cross-program activities and multiagency involvement need to be encouraged. Problem- oriented temporary task groups from various agencies should be formed to coordinate on specific issues. The EPA-FDA task group on the effects of pesticide residues on children is a good example.

    The interagency Task Force on Environmental Heart and Lung Disease and Cancer had a productive working group on risk communication that developed many effective workshops and publications. It provided a mechanism for interagency funding of projects of common interest and could be a model for interaction on risk-assessment issues.

    Support of Future State and Local Efforts

    Flexibility is crucial. EPA has adopted more flexibility in negotiating specific objectives with each state. Block grants have been proposed for other federal-state activities and are not new (health programs were funded through block grants in the 1970s). Block grants provide flexible funding and cut administrative costs. However, there is a need to guard against consumption of money by routine activities at the expense of innovation.

    In South Carolina in the 1970s the development of preventive public-health programs for chronic diseases would not have been possible without special funding outside the block-grant program. Special funding was provided through grants and cooperative agreements with NIH and CDC. With the special funding came a great deal of interaction with other states and experts from the science community. The CDC programs actually assigned a public-health advisor to the state. Technical support was also provided by such programs as the National High Blood Pressure Education program.

    Those research and demonstration funds provided funding to define the problems and evaluate the effectiveness of intervention strategies. The efforts encouraged state funding for services and provided an effective means for building capacity at the state level.

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