Chapter 2

The Framework for Environmental Health Risk Management

Much of the progress our nation has made in improving the quality of our environment and our workplaces, as well as the safety of pharmaceutical drugs, food, and other consumer products has relied on effective risk management. In the environmental arena, however, statutes and legal precedents tend to dictate risk management approaches that focus on one type of risk (e.g., cancers or birth defects in humans) posed by a single chemical in a single medium (air, water, or land). Conclusions about risk are based almost exclusively on observations of toxicity from high doses of the chemical in laboratory animals or in the workplace. While these approaches have reduced health, safety, and environmental risks in recent decades, they are not adequate for solving the more complex risk problems we now face.

Creative, integrated strategies that consider multiple environmental media and multiple sources of risk are needed if we are to sustain and strengthen the improvements attained in recent decades. Developing these strategies requires a risk management approach that addresses the interdependence and cumulative effects of various problems, engages a wide range of stakeholders, and enables the setting of priorities. To help meet these needs, the Commission has developed the systematic, comprehensive Risk Management Framework, illustrated in Figure 2.1. The Framework has six stages:

1. Define the problem and put it in context.

2. Analyze the risks associated with the problem in context.

3. Examine options for addressing the risks.

4. Make decisions about which options to implement.

5. Take actions to implement the decisions.

6. Conduct an evaluation of the results of the action.

The Framework is conducted:

• In collaboration with stakeholders.

• Using iterations if new information emerges that changes the need for or nature of risk management.

This Framework is designed to help all types of risk managers—government officials, private sector businesses, individual members of the public—achieve good risk management decisions, as defined on page 9 (Principles for Risk Management Decision-Making).

The Framework is general enough to work in a wide variety of situations. The level of effort and resources invested in using the Framework can be scaled to the importance of the problem, potential severity and economic impact of the risk, level of controversy surrounding it, and resource constraints. The Framework is primarily intended for risk decisions related to setting standards, controlling pollution, protecting health, and cleaning up the environment. It is useful for addressing these types of decisions at a local community level (e.g., siting an incinerator or cleaning up a hazardous waste site) or a national level (e.g., developing a national program for controlling motor vehicle emissions). The Framework need not be invoked for risk situations that are routinely and expeditiously managed—for example, by hazardous materials response teams, emergency room physicians, firefighter rescue teams, and voluntary product recalls.

Every stage of the Framework relies on three key principles:

• Broader contexts. Instead of evaluating single risks associated with single chemicals in single environmental media, the Framework puts health and environmental problems in their larger, real-world contexts. Assessing problems in context involves evaluating different sources of a particular chemical or chemical exposure, considering other chemicals that could affect a particular risk or pose additional risks, considering similar risks, and determining the extent to which different exposures contribute to a particular health effect of concern. The goal of contextual assessment is to clarify the impact that individual risk management actions are likely to have on public health or the environment and to help direct actions and resources to where they will be most effective.

• Stakeholder participation. Involvement of stakeholders—parties who are affected by the risk management problem—is critical to making and successfully implementing sound, cost-effective, informed risk management decisions. For this reason, the Framework encourages stakeholder involvement to the extent appropriate and feasible during all stages of the risk management process. The means and value of involving stakeholders are discussed on page 15.

• Iteration. Valuable information or perspectives may emerge during any stage of the risk management process. This Framework therefore, gives risk managers and stakeholders the flexibility to revisit early stages of the process and to revise earlier deliberations and decisions in light of new findings. The Importance of Iteration on page 32 provides more information.

Each stage of the Framework is described below, followed by recommendations to Congress and the Administration for facilitating its implementation.

Defining Problems and Putting Them in Context

The problem/context stage is the most important step in the Risk Management Framework. This stage involves five components, described in detail below:

• Identify and characterize an environmental health problem, or a potential problem, caused by chemicals or other hazardous agents or situations.

• Put the problem into its public health and ecological context.

• Determine risk management goals.

• Identify risk managers with the authority or responsibility to take the necessary actions.

• Implement a process for engaging stakeholders.

 

1. Identify and Characterize the Problem

An environmental or human health problem may already be well recognized or may be a latent problem. Ideally, problems will be anticipated and addressed at a very early stage, through such methods and indicators as:

• Emissions inventories; (e.g. the Toxic Release Inventory).

• Environmental monitoring, such as measuring concentrations of solvents that pollute ground water.

• Biological monitoring, such as measuring children’s blood lead levels or anemia.

• Toxicity testing in laboratory animals to help identify chemicals that might pose risks to humans or ecosystems.

• Toxicity testing using sentinel species in the environment to help identify the impacts of pollution on ecosystems.

• Disease surveillance, such as observing increases in the occurrence and severity of asthma or noting regional differences in the rates of a particular cancer or birth defect.

• Epidemiologic studies,such as observations of workplace exposures and particular disease rates.

• Lack of compliance with local or national standards to control contaminant concentrations in air, water, soil, or food.

• A permit application or a violation of a standard or permit (e.g., facility siting, wastewater discharge).

• A bad odor, as in communities where gasoline additives (oxygenated fuels) were used to reduce carbon monoxide emissions from automobiles.

• Community reaction, as may result when an agency decides to build a municipal solid waste incinerator in a neighborhood that was not consulted about the decision.

• Media or environmental activist reports about a risk based on preliminary or incomplete information that arouse public concern.

Characterizing a problem involves investigating both cause and effect. For example, it 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

• What is the problem? Why is it a problem? How was it first recognized?

• What types of adverse effects might the problem cause? Are they reversible?

• How imminently might the effects be experienced? In other words, are the effects likely to appear in the near future, later on in life, or in future generations? How urgent is the need for action? For example, a tank car carrying flammable solvents that overturns in a suburban neighborhood requires immediate attention (and therefore does not require implementation of this Framework); a municipal solid waste incinerator operating normally in the same neighborhood can be assessed more deliberately.

• How do stakeholders perceive the hazard? Do different groups of stakeholders have different perceptions and concerns? For example, parents of children at risk from exposure to an industrial pollutant may feel quite differently about a hazard than workers whose income depends on the facility causing the problem. When these are the same people—that is, the parents are also the workers—perceptions of the hazard can be quite complex.

Exposure

• Who may be exposed? Does the exposure pose different risks to different groups? For example, are the elderly, children, immunosuppressed individuals, or certain ethnic groups at greater risk than others due to age; medical, genetic or socioeconomic factors; diet; or activity patterns?

• What are all the relevant sources of exposure? How much does each source contribute to the problem?

• Are the exposures likely to be short- or long-term? What is their frequency?

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:

• By waste haulers as the result of inadequate landfill space.

• By local government officials as inadequate recycling of residential or industrial waste.

• By environmental advocates as too much waste generation.

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 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. Until recently, Resource Conservation and Recovery Act land-disposal regulations restricting intrasite movement of wastes may have increased risks and costs for Superfund site cleanups by requiring the trucking of wastes to off-site incineration facilities. 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. Since 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 released to the air from a nearby power plant, but might also be breathing hydrocarbons residents 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 page 13 for elaboration.

• 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 14 for elaboration.

• 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 either produce alone. For example, hydrocarbons are usually attached to very small particles, which can increase cancer risk and which can also 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 14 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 other risks to public health.

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, and the rationale for their identification, should be incorporated into the risk analysis (see How Should Risks Be Analyzed? on page 21).

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 do not 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 (EPA 1993a).

Motor vehicles contribute 60, 94, 33, and 39 percent 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 the use of reformulated gasoline 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 it assesses the residual risks from industries and compares them 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 the air. In fact, motor vehicle emissions are the largest single source of airborne benzene in the United States, and the risk from mobile sources and other important benzene emission sources such as cigarette smoke and consumer products used at home could be compared to the residual risk from refineries. 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 from other sources, risk-reduction efforts should focus on refinery emissions. If the refinery risk proves insignificant, however, 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 ground water near marine oil terminals. Benzene levels were measured inside homes near such a 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 Multisource 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 their 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, and 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, 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 Multisource 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. To develop effective solutions, risk managers must consider these problems in multisource and multirisk contexts.

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.

3. Identify Risk Management Goals

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

• Reduce or eliminate risks from exposure to hazardous substances.

• Reduce the incidence of an adverse effect.

• Reduce the rate of habitat loss.

They may be economic, aiming to:

• Reduce the risk without causing job loss.

• Reduce the risk without reducing property values.

They may involve public values, aiming to:

• Protect the most sensitive population.

• Protect children.

• Preserve a species from extinction.

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 guide the rest of the decision-making process.

4. Identify Risk Managers

The risk manager is the person responsible for managing the problem. Who is the most appropriate risk manager 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. Although it is preferable to resolve the issue of who should be the risk manager or managers at this stage, who the risk manager should be may not become evident until the risk management options are identified. Often, risk management responsibilities can be shared or may evolve with changing circumstances.

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

5. Establish a Process for Engaging Stakeholders

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 7 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.

• In the case of a contaminated site, stakeholders include those whose health, economic well-being, and quality of life are currently affected or would be affected by the cleanup and the site’s subsequent use. Also included are those who are legally responsible for the site’s contamination and cleanup, those with regulatory responsibility, and those who may speak on behalf of ecological considerations or future generations.

• In the case of an application for a pesticide reregistration, stakeholders include the pesticide manufacturer, owners of the farms where the pesticide is used, laborers who apply the pesticide, consumers who may be exposed to pesticide residues in foods, scientists who seek further pesticide research funding, trade associations like the Grocery Manufacturers’ Association, those who speak on behalf of ecological considerations, and those with regulatory responsibility.

• In the case of a substantial decline in the oyster population in a bay because chemicals have been carried into the bay from farms and roads, stakeholders include the people who harvest the oysters, retailers, consumers, dairy farmers, pesticide manufacturers, manufacturers of automobile emissions control devices, local communities, those who speak on behalf of ecological considerations, and, of course, those with regulatory responsibility.

Questions that can help identify potential stakeholders include:

• Who might be affected by the risk management decision? (This includes not only groups that already know or believe they are affected, but also groups that may be affected but as yet do not know it.)

• Who has information and expertise that might be helpful?

• Who has been involved in similar risk situations before?

• Who has expressed interest in being involved in similar decisions before?

• Who might be reasonably angered if not included?

Thus, stakeholders may include:

• Community groups.

• Representatives of different geographic regions.

• Representatives of different cultural, economic, or ethnic groups.

• Local governments.

• Public health agencies.

• Businesses.

• Labor unions.

• Environmental advocacy organizations.

• Consumer rights organizations.

• Religious groups.

• Educational and research institutions.

• State and federal regulatory agencies.

• Trade associations.

 

Why Is Stakeholder Involvement Important?

Experience increasingly shows that risk management decisions 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 percent 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 enables 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 about the considerable costs and additional time needed to involve stakeholders in risk management. However, risk management by government agencies has generally been costly anyway, and investment in stakeholder involvement can bring long-term savings, especially when it 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.

How Can Stakeholders Be Engaged?

The Risk Management Framework promotes at least some stakeholder participation at each stage of the 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, while others are not. In all cases, however, risk managers should work to:

• Identify all stakeholder groups as early as possible in the process, beginning with the problem/context stage.

• Determine the optimal process for stakeholder involvement.

Offering 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. At times, 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:

• Complexity, uncertainty, impact, and level of controversy associated with the decision to be made.

• Urgency with which the problem must be addressed.

• Extent to which participants can have a genuine influence on the decision. If the decision is really not negotiable, stakeholders’ time should not be wasted.

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, and why. Nonetheless, we developed a number of guidelines for effective stakeholder involvement based on the experiences practitioners shared with the Commission. Those guidelines are described in the box on page 17 (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 drew far fewer legal and scientific challenges than 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 potential health risks associated with recontamination by fugitive dust from the waste pile remaining at the smelter, which EPA was not going to remove.

• The health risks posed by fugitive dust from the trucking lot adjacent to the waste pile, which EPA was also not going to remove. This soil was contaminated with 50,000 parts per billion of lead.

• The common presence of lead-based paint in the area, which a local study suggested was the most important source of exposure to lead for children.

• The fact that 95 percent of the children had blood lead levels below 15 µg/dL.

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.

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