United States
              Environmental Protection
              Agency
               Prevention, Pesticides,
               And Toxic Substances
               (7507C)
vvEPA
Ecological Risk:
A Primer For Risk Managers
EPA 734-R-95-001
January 1995
     **•» "s f1 ~i

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        Ecological Risk:

 A Primer for Risk Managers
           Prepared for

The Agency Ecological Risk Management
       Communication Group

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                             This document was prepared by:

 Office of Prevention. Pesticides and Toxic Substances

       Ingrid Sunzenauer, Environmental Fate and Effects Division, Office of Pesticide
       Programs

       Mary Powell, Environmental Fate and Effects Division, Office of Pesticide Programs

       Candy Brassard, Environmental Fate and Effects Division, Office of Pesticide
       Programs
                                                                i
       Don Rodier, Risk Analysis Branch, Chemical Screening and Risk Assessment
       Division, Office of Pollution Prevention and Toxics

       Lynne Blake-Hedges, Regulatory Impacts Branch, Economics, Exposure and
       Technology Division, Office of Pollution Prevention and Toxics

       Special thanks to Elizabeth Resek, Environmental Fate and Effects Division,
       Office of Pesticide Programs, for her time and effort in creating the front cover.

Office of Water                                                  1

       Suzanne Marcy, Health and Ecological Criteria Division, Office of Science and
       Technology

Office of Policy. Planning and Evaluation

       Michael Brody,  Science Policy Staff, Office of Regulatory Management and
       Evaluation

Office of Research and Development                              ;

       Anne Sergeant, Office of Health and Environmental Assessment

Office of Solid Waste and Emergency Response                     |

       Jeff Langholz, Toxics Integration Branch, Hazardous Site Evaluation Division, Office
       of Emergency and Remedial Response (Superfund)

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We travel together, passengers on a little spaceship, dependent on its vulnerable
supplies of air and soil; all committed for our safety to its security and peace,
preserved from annihilation only by the care, the work, and I will say, the love
we give our fragile craft.                                    ,
                                                        Adlai E. Stevenson
                                                  former U.N. Ambassador

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                           Table of Contents

 1.  An Introduction	  5

 2.  Why We Value Ecological Resources	  7

 3.  The Risk Manager's Role in Risk Assessment:         ;
       Where Do You Fit In?	 10
       The Need For Planning	10
       The Basic Elements of Problem Formulation	 . 11
       Taking The First Step		12

 4.  What to Protect:  How Do You Select
       Assessment Endpoints?	15
       Selecting What To Protect	15
       Past and Future Assessment Endpoints	18
                                                    i

 5.  How To Measure Value:  Let's Talk Dollars and Sense J	21

 6.  Risk Decision-making:  How Do You Make Up Your Mind?	  24

 7.  Communicating Risk: How Do You Explain
       A Risk Management Decision to Others?  	28
       Tailor Risk Communication to Your Audience	28
       Describe the Ecological Resources at Risk and
            Communicate Their Value	  29
      Describe the Risk	30
      Discuss  Options for Reducing Risks	31
      Work With the Media	  ........  31

 8.  Conclusions: Where Do We Go From Here?	.  . „	32

References  	33

Suggested Readings	   35

The Agency Ecological Risk Management Communication Group	36

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            Ecological Risk:  A Primer for Risk Managers

                                 Chapter 1

                              An Introduction

       The integrity of ecological resources is directly linked to human
 welfare.  Over the last two decades, many have increasingly come to recognize
 this link. As the Science Advisory Board stated (U.S. EPA, 1990), "Human
 health and welfare ultimately rely upon the life support systems and natural
 resources provided by healthy ecosystems."

       Concern about the rapid changes and degradation of ecosystems led to
 the first Earth Day in 1970 and formation of the EPA.  This was followed by
 significant environmental legislation including the Endangered Species Act
 (ESA), Clean Water Act, Clean Air Act, and Toxic Substances Control Act.

       Initially, EPA focused most of its efforts on protecting human health
 (U.S. EPA, 1990).  Although ecological impacts are now considered to a
 gfeater extent, human health remains a  major focus.  As a result of this
 historical emphasis, many risk managers have had  more experience in
 incorporating human health concerns than ecological  concerns into the risk
 decision-making process. Also, different environmental statutes require
 different degrees of consideration of ecological risk.
                                                          I
                                                          I
       Some risk managers in EPA have indicated that they would like to
 consider ecological risk to a greater extent, but they do not understand the risk
 assessments they receive. They also indicated that the assessments can be
 complicated and confusing.  In contrast, others understand the assessments, but
 have indicated that they do not always provide the  information  needed to make
 a decision (U.S. EPA, 1993a).

       Specific questions that have been raised by risk managers throughout
EPA include:                                              ,

       •     How are ecological resources valuable  from an ecological, social
             and economic point of view?

       •     What resources should be protected,  and how should effects to
             these resources be measured?
                                                          i
       •     How can risk managers and the public  be more involved in the
             risk assessment process?

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       The answers to these questions add to an already complex decision-
making process, in which a great deal of information and its associated
uncertainties and limitations must be considered.  Economic, political and
social considerations often must be addressed, as well. Also, the EPA focus is
shifting to a more holistic, ecosystem approach to ecological nsk management
(U S  EPA, 1993b, 1993c, 1994a).  All of these issues underscore the need for
comprehensive risk assessments to address the needs of the decision-makers
more definitively.

       This document intends to help EPA risk managers use ecological risk
assessments more effectively  by providing some insights into the three
questions outlined above.  The document is meant to be easy to read and to
provide a general context for ecological risk decision-making.  It is not meant
to replace the many other documents that are already available  or under
development, such as more technical and detailed risk-assessment guidance
(see References and More Suggested Readings). Nor does the  Primer address
place-based management of risk to ecosystems; that may be the topic of a
future document.

       Although this is an introductory document that contains a great deal of
basic information, we hope that those with more experience in ecological risk
 management will still gain from some of the ideas and suggestions that follow.
 This document will cover how to:

        •      consider the values of ecological resources (see chapters 2 and
               5);

        •      understand risk managers' involvement in the risk assessment
               process and determine what resources should be protected (see
               chapters 3 and 4); and                                   ;

        •      use a risk assessment for risk decision-making,  communicate
               that risk to others, and listen to the public to understand their
               views (see chapters 6 and 7).

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                                  Chapter 2               :

                     Why We Value Ecological Resources

        On May 7, 1984, 700 brant geese were found dead on a golf course on
  Long Island, New York.  They had been poisoned by a pesticide known as
  diazinon.

        EPA began investigating other wildlife kills attributed to diazinon
  Through the efforts of the New York Department of Environmental
  Conservation, the agency received 51 more reports of bird kills on turf in 15
  states and one Canadian province.  The numbers of dead birds  in the reports
  ranged from one goose to about 800 to 1,000 wigeons.  Twenty of the
  incidents occurred mainly or entirely on golf courses; the remainder occurred
  mainly or entirely on other turf sites.

        Following investigations, EPA concluded that the risk to birds from
 diazinon  use outweighed its benefits to golf courses and sod farms.  In March
  1988, EPA canceled the use of diazinon on those two sites,   i
                                                          i
        The agency's decision on diazinon marks a victory for preserving  the
 intrinsic value of an ecological resource - the various species of birds.
 Indeed, the U.S. Court of Appeals Fifth Circuit determined in its decision that
 the agency "had discretion to find recurring bird kills to be unreasonable
 environmental risk" (Ciba-Geigy Corp. v. U.S. EPA, 1989).

       Although it is often taken for granted, or sometimes not  even thought
 about at all, our lives depend on a healthy, functioning environment.  Yet
 many of the resources humans depend on for a healthy life have been,  or are
 being, contaminated.  For instance, many food sources today, such as'fish,
 have become so laden with contaminants that advisories against  their
 consumption are commonplace, where they once were rare.
                                                          i
       These effects of  chemicals on wildlife may serve as a harbinger of
 potential human health problems.  Consider DDT:  This and other
 environmental estrogens act by interfering with estrogen production and
 function, and recent evidence indicates that environmental estrogens can cause
 adverse effects that may vary among species and chemical (Cotborn et al
 1993; Fox, 1992; Guillette and Gross, 1994).  Possible adverse effects on'
humans from environmental estrogens mirror those found in other species  and
include decreased male fertility and increased female reproductive
abnormalities (Hileman,  1994).

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       A balanced ecosystem is a diverse environment, yet the biodiversity on
earth is rapidly decreasing. Humanity co-evolved with the rest of life, so it is
imprudent to suppose that biodiversity can be diminished indefinitely without
threatening humanity itself.  No one can fail to appreciate the contributions of
various plants and animals to such human necessities as medicine and
agriculture.  We derive more than 120 prescription  medicines from plants, and
more than a third of these come from rain forests (Harms, 1994).  Most of our
"miracle drugs," like antibiotics, originated  from plants and fungi. For
example, Taxol, derived  from  the Pacific yew tree, has cancer-fighting
qualities.  Modern agriculture  still depends on native plants for genetic
material to maintain and  improve food supplies.  For instance, a perennial wild
relative of maize can be bred with agricultural hybrids to instill disease
resistance and climate tolerance (Wilson, 1992).  Yet in spite of tremendous
strides in knowledge about ecosystem function and  structure, much remains to
be learned, such as the role of various species, both prominent and
nondescript,  on the planet.

       Population biologists Paul and Anne Erlich liken the need to maintain
biodiversity to the rivets  on an airplane:  Each rivet plays a small but
significant role in the workings of the entire plane.  "The loss of each rivet
weakens the plane by a small but noticeable amount until it loses airworthiness
and crashes" (Erlich, 1981).
       In addition to humans'
 physiological dependence on
 a healthy environment, there
 is an appreciation of the
 planet's ecological resources
 that is evinced by recreational
 values including fishing,
 hunting, bird watching,
 nature study, hiking and
 swimming.  These activities
 both enhance the quality of
 human life and promote a
 strong economy through
 tourism and recreation.
 More and more vacations are planned around natural areas such as parks and
 waterside properties.  Ecotourism to our national parks and other unique
 ecological habitats,  such as visiting the Galapagos Islands to observe many;
 species not found in other parts of the world, has grown significantly over the
 last decade. One way in which EPA improved the aesthetic quality of our
 natural resources was by requiring the installation of scrubbers in the Navajo
 Generating Station,  Arizona, to improve visibility at the Grand Canyon.
         Gauging the Values
       of Ecological Resources

In managing ecological risk, consider
the effects of actions on;
       biodiversity
       ecosystems
       recreation or culture
       aesthetics
       human life support
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       In recent decades, environmental concerns have driven decisions and
policies that led to notable successes in addressing ecological risks.  Where
once there was rote spraying of pesticides, there now is increased public
awareness of their hazards.  The use of integrated pest management, including
increased reliance on non-chemical pest control strategies, is increasing.
Where once there was  unabated pollution of rivers,  technology and regulations
have begun to ameliorate past mistakes. Tremendous strides  have been made,
but the trend needs to be continued.  Chapter 3 examines your role, as an EPA
decision-maker, in that continuation.

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                                Chapter 3

    The Risk Manager's Role in Risk Assessment: Where Do You Fit In?

       To obtain the answers you need from a risk assessment, you have to
take part in its design. Although risk management and risk assessment usually
are considered separate and distinct activities, they were never intended to be
mutually exclusive activities devoid of any interaction or communication
whatsoever (National Research Council, 1983). The two activities were
separated to prevent political and special-interest pressures from interfering
with EPA's  scientific analyses and conclusions.

       The need for interaction between risk assessors and risk managers
became even more apparent when peer reviewers for the agency's Framework
For Ecological Risk Assessment repeatedly stressed the importance of an active
dialogue between risk assessors and risk managers (U.S. EPA, 1992a), as well
as the public.  The result was the creation of a formal step in the ecological;
risk assessment process  known as problem formulation.  Problem formulation
is a systematic planning exercise that involves  the risk assessor and risk     :
manager. It precedes the analysis and risk characterization phases, which   ;
generally are the responsibility of the risk assessor.                        >

       A. The Need For Planning

       The potential complexities of an ecological risk assessment demand
careful planning for its design.  Many of the complexities differ from those of
human health assessments, and include deciding what species, ecosystems or
functions to protect; species interactions and indirect effects; the significance
of non-chemical stressors; and legal considerations.                       i

       Ecological risk assessments often evaluate effects to more than one
species and  level of ecological organization. Often a given stressor, such as a
chemical, may affect a species not only directly (for example, by mortality),
but may affect it in subtle ways, such as reducing its food supply or altering
its  habitat.  For example, large-scale mortality of earthworms induced by
pesticides can devastate birds that depend on those earthworms for food. The
timing of those kills (such as during the bird breeding season) is also critical.
These indirect effects often are far more insidious and important than direct
effects, but  neither direct nor indirect effects are easily quantifiable.

       Risk assessments in EPA have largely been concerned with chemical
stressors. Especially as the agency's  focus changes toward ecosystem
management, there is a  growing awareness that more attention has to be paid
to non-chemical stressors such as habitat alteration, global climate change, and


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 bioengineered and introduced organisms.  Assessing non-chemical stressors
 may require a different approach than the traditional risk paradigm used for
 chemical stressors.  The temporal and spatial scales may also differ
 tremendously from those for chemical stressors.  In addition, chemical and
 non-chemical stressors may act in concert when both are presisnt.

        Legal considerations vary among EPA programs and must be addressed
 in risk management questions.  Both the qualitative and quantitative values of
 our ecological resources are reflected in the myriad statutes and executive
 orders that require EPA to protect those resources.  Some of those
 requirements are more stringent than others.  For instance, in many cases,
 water-quality criteria to protect aquatic life are more stringent than drinking
 water standards designed to protect human health.  Some statutes, such as the
 ESA, mandate direct responsibilities to EPA,  even though we are not the
 primary agency for implementing the statutes.

        All of this brings us back to the need for careful planning. Problem
 formulation provides a means for developing a logical and sequential approach
 to solving a complex problem.  It is the time for you,  the risk assessor and the
 public to identify the issues that are germane to a particular stressor and
 develop a plan to assess its risk. Problem formulation also is the time for
 identifying the appropriate methodologies for assessing the identified concerns.

        B.  The Basic Elements of Problem Formulation
                                                          I
        Problem formulation includes several critical steps.  Orie of the most
 important is identifying and selecting assessment endpoints and measurement
 endpoints (see chapter 4).  Suter (1993) defined effective assessment endpoints
 as those that identify "the valued attributes of the environment that are
 considered to be at risk."   Although discussions continue about the appropriate
 meaning of "value" in this definition, it is interpreted to mean that the focus of
 a risk assessment should be on ecological resources that are vsiluable because
 they are protected by law;  because they provide critical resources; or because
 their alteration has impaired, or would significantly impair,  ecosystem
 function. The measurement endpoint is a measurable ecologicfil characteristic
 or some response that is related to, and lets you learn about, the assessment
 endpoint (U.S. EPA,  1992b).  Ideally, these endpoints are the'same; but often,
 adverse effects on assessment endpoints cannot be measured directly. For
 example, if the value of concern is maintaining a  sport fish population within
 20 percent of a 20-year average, the assessment endpoint may be estimated
when the fish population can  be measured directly and  changes in population
 may be directly related to the stressor of concern.  However, it may be very
difficult to measure fish populations (such as anadromous fish) directly. When
this is the case, individual response to a stressor may serve as the
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measurement endpoint. Population effects may then be inferred using a model
or expert judgment.

       In addition to identifying assessment and measurement endpoints,
problem formulation allows you and the risk assessor to develop a plan on how
to assess the ecological risks of a certain stre'ssor.  Important components of
the plan include identifying methods for the analysis phase and determining
how to conduct the risk characterization.  Another important component is
establishing the need for public involvement in the risk assessment process.
Public involvement is the key to ensuring that the risks assessed are
understood and valued by the community and that effective risk communication
occurs between the agency and the public (see chapter 7).

       C.  Taking The First Step

       As interactive partners in problem formulation,  you, the risk assessor
and the public should:

       Understand what to protect and what to  protect it from.  The
ultimate goal of ecological risk management is to protect a resource.  You
need to agree on assessment endpoints, and understand the relationship
between these and the measurement endpoints. Be familiar with relevant   !
program statutes and policies, and be able to ascertain if the assessment
endpoints are compatible with them. If indirect effects (for example,  effects
on food, habitat or interacting organisms) are to be assessed, make sure you
understand the implications of both those effects and the methods that will be
 used to evaluate them.

        Agree on the scope of the assessment. Risk assessments can vary in
 complexity from simple, screening-level, short-term ones to complex, long-
 term ones. The process can identify existing risks or forecast the risks of
 stressors not yet present in the environment.  An example of a simple
 assessment is the quotient-type assessment done for 1,800 new chemical
 submissions a  year in EPA's Office of Prevention, Pesticides and Toxic
 Substances (OPPTS). In those, the ecological risk assessment  of a chemical
 consists of comparing its predicted concentrations in an aquatic environment
 with its predicted toxicity values  in that environment.  A resulting quotient of
  1 or more may trigger some regulatory decision,  such as requiring further tests
 or imposing use restrictions to reduce or eliminate exposure.  An example of a
 complex assessment is EPA's nine-year effort to evaluate the risks of     ;
 contamination in Commencement Bay, Washington.  That assessment entailed
 extensive monitoring of the affected areas and biota, and analysis of the
  feasibility of clean-up options. The risk assessment involved other federal
  agencies and state and local governments.                               ;

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       Even with screening-
 level analyses, the risk
 assessment process is often
 iterative; that is, a risk may
 be identified using minimal
 data and perhaps conservative
 assumptions.  This level of
 analysis may prompt the need
 for additional data and
 another risk assessment.
 Depending on the quality and
 quantity of information
 available, additional iterations
 may be necessary.  But first,
 you and the risk assessor
 must agree on the initial
 scope of the assessment,
 recognizing that additional
 analyses may be necessary.

       Consider the
 limitations of the risk
 assessment.  Despite the
 considerable uncertainty
 inherent in them, cancer risk
 assessments are often
 presented as being very
 precise and may have set an
 inappropriate precedent.
 Although ecological risk
 assessments can be highly
 quantitative, the relationship
 of measurement endpoints to
 assessment endpoints may not
 be. Regulatory action may
 have to be based on
 measurement endpoints, not
 on assessment endpoints.
 The risk assessor should clearly articulate the limitations and uncertainties of a
particular assessment. This is true regardless of the simplicity or complexity
of the proposed assessment.

      At a minimum, you should receive from the risk assessor the following
information about a particular methodology: past regulatory use; assumptions
 Some Questions All EPA
Risk Managers Should Ask
 Has anyone previously
 this or a related issue?
 What parts of the ewsystexn tnay
 be vulnerable?

 What are the assessment and
 measurement endpoiats, and how
 are they related?

 How long will the assessment
 take?

 What scientific disciplines* EPA
 offices or other federal agencies
 need to be involved?
Is there a need for
involvement?
What are the uncerfciinties in the
assessment?

What is the significance of the
predicted effects to ecosystems^
populations or humans?

Will the  risk assessment support
the comparison of risk mitigation
options?

Is there a need for monitoring?
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that will be used, such as those about natural mortality and birth rates when;
actual data are not available; other data gaps; the peer review status of the
methodology; and its hardware, software and personnel requirements.

       Plan to have the risk assessment be compatible with the risk/benefit
or risk mitigation analyses.  Traditionally, risk/benefit analyses have weighed
the risks of a particular  stressor against its benefits to some portion of society.
As discussed in chapter  2, there is an increasing awareness of the importance
of ecological resources that may be affected by stressors.  In most EPA
programs, economic analyses can play an important role in weighing the risks
and benefits of stressors on a given resource; therefore, economic analyses  !
should be compatible with the assessment and measurement endpoints.
Likewise, an evaluation of risk mitigation options may require that the
measurement endpoints, or even the format of the risk assessment report, be
compatible with the yardsticks that would be used to evaluate risk mitigation
options. The risk assessor must understand the problem and ascertain how the
results of anticipated economic or risk mitigation analyses will complement the
ecological risk assessments about to be conducted.

       Recognize the connection between human health and ecological  ;
issues.  For expediency, EPA programs typically have been organized to focus
on human health or ecological assessment.  Keep in mind that the relationship
between the well-being  of humans and the environment is a closely knit one.
The well-documented incidence of methyl  mercury poisoning of biota and
humans in Minamata Bay, Japan  is an example.  In the early 1950s, fish kills
and neurotoxic effects were observed in birds and cats before symptoms of
methyl mercury poisoning appeared in the human residents of Minamata.

        No single program in EPA can provide complete protection from all
stressors. However, our legislative mandates require consideration of both
human and  environmental health; therefore, you must give appropriate weight
and attention to both.  Consult with the human-health risk assessors.  Many
times there is significant overlap  between data needs, and a little up-front
planning can ensure that the data collected are suitable for assessing risk to
both the environment and human health.

        Now, how do you determine what to protect in a risk assessment?
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                                 Chapter 4               \

         What to Protect: How Do You Select Assessment Endpoints?

       As a risk manager, one of your principal decisions in an ecological risk
 assessment concerns which ecological resources to protect.  Often, in seeking
 to protect ecosystems, the focus must become a particularly  vulnerable
 component of that system, say, an endangered species or a bckly of water.
 The choice of components is vast, and may be different in each risk
 assessment.  This choice can make deciding what to protect  difficult, but it is
 critical for effective use of ecological risk assessments in risk management
 decision-making. During problem formulation, your input in selecting what to
 protect is essential.

       A. Selecting What To Protect

       The ecological resources you select to protect become the assessment
 endpoints that drive ecological risk assessments. EPA (1992b) identified three
 principal criteria to consider when selecting assessment endpoints:
                                                         i
       •     ecological relevance,                        i

       •     susceptibility to the stressor, and             \

       •     societal values and policy goals.              :
                                                         i
 Assessment endpoints that meet all three criteria provide the best foundation
 for an effective risk assessment (see the box on salmon and hydropower).
                                                         i
       Ecological relevance. Ecological relevance refers to whether resources
 help sustain the natural structure and function of an ecological system.  Species
 are considered ecologically relevant when they provide a significant food base,
 maintain community structure, provide shelter for other species, promote
 regeneration of critical resources, or serve some other important function in
 the ecosystem. Species that clearly influence these ecological characteristics
 are good assessment endpoints.
                                                         I
       Ecological relevance becomes most important when risk assessors are
identifying the potential cascade of adverse effects that could result from the
loss or reduction of one or more species. A strong understanding of the
ecosystem potentially at risk is therefore essential and must inifluence
assessment endpoint selection.
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       Susceptibility to the
stressor.  Ecological risk
assessment requires a broad
interpretation of
susceptibility.  Ecological
resources are only considered
susceptible to a human-
induced stressor when they
are sensitive to a stressor to
which they, or some of their
resources, are exposed.

       Sensitivity refers to
the likelihood that one
individual or species may be
more or less affected by  a
particular stressor than
another.  The hazard
identification process
represents measures of
sensitivity to toxic chemicals.
Sensitivity includes endpoints
such as mortality or adverse
reproductive effects from
exposure to toxics.  It can
also include behavioral
abnormalities, avoidance of
significant food sources or
nesting sites, or loss of
offspring to predation because
of the proximity of stressors
such as noise, habitat
alteration or loss, community
structural changes, or other factors.

       Exposure is the other major variable in susceptibility. The proximity
of an ecological resource to the stressor and the frequency and duration of
exposure must be considered.  If a species is unlikely to be exposed to the
stressor of concern, that species is not an appropriate assessment endpoint.

       Proximity in space can mean co-occurrence, contact, or the absence of
contact,  depending on the stressor and assessment endpoint. For example, a
highway through a wetland may be enough to drive off roosting birds because
the birds are disturbed by traffic noise and headlights.  Direct contact with the
      Salmon andHydropower:
    Selecting Endpoints that Work

       Salmon species are being
depleted In the Atlantic and Pacific
oceans, due in patt ft a loss of spawning
areas in freshwater streams and rivets
along the coasts. When evaluating  the
potential risk of a proposed
hydroelectric dam  to bejbuilt on a  river
containing salmon  spawning areas,
salmon recruitment would be an
apjpropriafe assessment endpoint because
it meets the three principal criteria for
selecting effective  assessment endpoints.
Young and adult salmon^represent       ;
important food sources for a multitude
of aquatic anjd terrestrial  species
(ecological relevance), Salmon are very
sensitive to changes In sedimentation
and substrate pebble size and have
difficulty climbing fish ladders.
Hydroelectric  dams *epresent
significant* and normally fatal, obstacles
to breeding salmon (susceptibility),
Finally, salmon support a large         ;
commercial fishery,  some species are
endangered, and they have ceremonial
importance and are key food sources for
Native Americans (societal value).     ]
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       T&t Mussel-Fish Connection
                           are
   highway is not required; thus,
   co-occurrence is sufficient to
   cause adverse effects. The
   presence of degraded habitats
   can also be translated into
   exposure .to unsuitable
   feeding, resting  or breeding
   habitat.  The spatial extent of
   these conditions is key to
   understanding the potential
  risk of habitat changes to
  assessment endpoints.

        Finally, susceptibility
  may increase or decrease as a
  result of an interaction
  between sensitivity and
  exposure.  For example, one
  life stage of an organism may
  be more sensitive to a
  stressor than others:
  Exposure to a stressor during
  egg development or adult
 reproduction may increase
 adverse effects because
 sensitivity is greater in these                              ___ —
 life stages. These interactions can become more complex when both direct
 and mdirect effects are considered.  For example, a sensitive Kfe stege o?l
 target species can be adversely affected by the loss of or change inSother

            1S SUSCe                                           FM
       ^
 endangered In              .
 Management efforts have foeised on
 Jftamtaiiirag suitable habits* for mussels
 because habitat loss 1m tjuen 
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       Resources of ecological relevance often are not considered valuable  ;
because humans are indifferent to them or find them annoying.  Midges  for
example, are considered pests, but can represent the base of a complex food
wel that supports a popular sports fishery. In this case, it wou d be better to
choose the fishery as the basis for a.risk assessment (assessment endpomt) and
select midges as a critical ecological component to measure (measurement
endpoint).
       Once you have
 selected an assessment
 endpoint, it must be clearly
 defined.  Assessment
 endpoints can be too broad,
 vague or narrow,  or can be
 inappropriate for the
 ecosystem requiring
 protection (see box).

        You can take a
 number of steps to include
 these goals and values in
 selecting your assessment
 endpoints. Work closely
 with the risk assessors during
 problem formulation.
 Determine what protection of
 ecological resources is
 required by federal law, and
 state and local regulations.
 Evaluate and select endpoints
 you can defend in support of
  your decisions.   Where
  appropriate, this is also the                                   .
  time to consider incorporating public concerns.  Evaluate the socio-economic
  status of the local people, determine their interests in the ecological resources
  and examine their economic interests.  Public meetings during this initial phase
  can be very useful in getting the public involved,  elucidating local concerns,
  and gaining support for the risk assessment process.

         B.  Past and Future Assessment Endpoints

         EPA has used a variety of endpoints to make risk management
  decisions in the past and is now considering others that reflect new mandates
  and program emphases.  To determine the range  of currently accepted
Common Attributes of Inappropriate
       Assessment Endpoints

      Endpoint fc too vague (e,gV,
      ecosystem integrity)

      Ecological resource is better as a
      ^measufement^endpoint (e,g.,
      midges)                   ,; „

 •     Ecological resource is not
      exposed to the stressor

 >     Ecological resource is irrelevant,
      or not directij related, to the   <
      assessment (e*g.> effects on other
      game fish in an at-risk sateion
       stream)
       Life history requirements       ,
       insufficiently considered {e.g,,    "|
       mussel-fish connection)
                                       18

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  assessment endppints, the agency reviewed those it has used in risk
  management decisions (U.S. EPA, 1994b). Categories of endpoints that were
  identified include groups of individuals, local populations, multiple species and
  habitats/ecosystems.  Threatened and endangered species encompass  a special
  category not considered here because of the clear legal mandate for protection.

         Groups of individuals.  EPA has not regulated against adverse effects
  to individual non-human organisms, except for threatened and endangered
  species, and no quantitative threshold for an unreasonable number of adversely
  affected individuals has been used in EPA. However,  EPA has used adverse
  ettects on groups of individuals exposed to chemical stressors (such as bird or
  fish kills).  One well-documented case in EPA's Office of Pesticide Programs
  is the cancellation of the use of diazinon discussed in chapter 2.
 T:T,A         p°Pulatioils- To date> when population analyses are used at
 EPA, they focus on declines or extinctions of local aquatic populations at
 particular sites, rather than on formal population-effect modeling  EPA
 typically has not considered dynamic population parameters such as birth
 death, and emigration or immigration rates in evaluating risk. Because of the
 limited available information, the effort required to characterize causal and
 temporal trends among stressors and populations has been expensive and time-


       Multiple species. Some EPA programs consider adverse effects on
 multiple species.  The most common such endpoints are aquatic  life water
 quality criteria (AWQC). These are developed by testing the sensitivity of an
 array of different species to a specific chemical. The use of AWQC implies
 that 95 percent of the species in a natural community would be protected if
 ambient waters meet an acute criterion.  The assessment endpomt is the
 integrity of the aquatic community, and the AWQC are threshold values based
 on toxicity testing.  Species interactions are not considered in these criteria
 In addition, the validity of an assumption that protecting the most sensitive
 species will protect a community or ecosystem is the subject of: scientific
 debate.
       Habitats/ecosystems. This category of assessment endtwints represents
concerns about an entire ecosystem and its values, rather than a particular
species.  EPA generally has not considered interactions among animal and
plant communities and their abiotic environment (ecosystems); however EPA
has focused on protecting specific habitats such as wetlands, riparian areas
estuaries and large geographic areas such as the Chesapeake Bay and Great
i^aic
                                   19

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       Assessment endpoints that reflect the dynamic nature of populations,
communities and ecosystems would add greater depth and insight to ecological
risk assessments in EPA.  These assessment endpoints are not widely used
now because analyses of population and ecosystem dynamics require
information about natural systems.  Such analyses can be resource-intensive
and difficult to model. However, these assessment endpoints better represent
risks to the ecological resources you are trying to protect and should be
incorporated more into future risk assessments.

       Endpoint selection is based, in part, on the societal value of the
ecological resources of concern. It may help to determine the economic value
of those resources.   The following chapter describes some methods for
characterizing the economic value of assessment endpoints.
                                     20

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                                  Chapter 5

             How To Measure Value: Let's Talk Dollars and Sense

        Some statutes require consideration of the economic effects of
 ecological risk decision-making, and dollars offer a convenient unit in which to
 measure the value of the resources involved. Although various! statutes
 consider money  in different ways, this chapter looks at some ways to measure
 the value of ecological resources  affected by a risk management decision.

        Just as the limitations of a risk assessment must be considered in a risk-
 management decision, so must the limitations of an associated (jconomic
 analysis. Although numerous tools are available to express the value of certain
 ecological resources monetarily, it is likely that, for a given case, a large
 portion of the value may be represented only qualitatively.  In such cases, it
 does not mean the values are any  less relevant or significant than those that
 have been monetized (assigned a dollar value).  It could be that techniques or
 data simply are not available that  allow monetization.

        A proposal by EPA's Office of Pollution Prevention and Toxics to ban
 certain kinds of fishing sinkers demonstrates a qualitative analysis of the
 benefits of risk reduction. Water  birds ingest such sinkers and  die from lead
 and zinc poisoning. The population impacts of such poisonings are not well
 characterized,  so the benefit analysis  described the numbers of birds potentially
 affected and the number of fishing sinkers potentially available in the
 environment. Because each  sinker represents a potential death,  the analysis
 also compared risk management options for their ability to remove sinkers
 (potential deaths) from the environment.  The analysis also provided evidence
 of the monetary value of potentially affected  birds, based on previous
 economic studies.                                           i

       The most  obvious way to measure the value of ecological resources in
 dollars is by observing sales  in the marketplace - quantities sold and prices,
 such as the cost per pound of commercially harvested shellfish.  However, not
all ecological resources are traded  in markets, so other approaches to
measuring their value are necessary.  Occasionally, the  replacement cost of
resources is used  as a proxy  for its market value.  Two other approaches are:

       •     Indirect market approaches.  These evaluate markets related to
             the resource.  For example, the travel cost method relates the
             monetary value of ecological resources (such as good water
             quality and a healthy sport fishery) to the amount  of money
             people spend using that resource (such as traveling to a fishing
             site, buying bait and paying boat fees).  Another indirect  market
                                    21

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              approach, hedonics, uses information embedded in property
              values to determine the value of environmental attributes. This
              method assumes that perceived differences in ecological      !
              attributes are factored into property prices.                  i

       •      Constructed market approaches, such as contingent valuation.:
              These approaches calculate monetary value by using hypothetical
              market scenarios and asking people how much they would be
              willing to pay for ecological resources.

       These and other techniques for monetizing ecological resources
'generally have some anthropocentric focus. From this perspective, values are
 often categorized as those that derive from human use, such as fishing and
 bird-watching, and those  that are independent from whether the resource is
 used by humans, but still appreciated by them.

        Values more difficult to associate with dollars include the value of
 biodiversity,  which generally has less direct or obvious linkages to human
 activity than  other types of values.  Also, traditional economic methods for
 monetizing values generally do not effectively address ethical considerations,
 such as whether resources are worth more to future generations,  and whether
 damage to ecological resources is long-term or irreversible.  These issues and
 values of ecological resources that cannot be related to some human activity
 are often presented qualitatively.  Some of the ways in which values can be
 monetized follow.

        Life support values of an ecosystem may be reflected in functions or
 services  that are difficult to measure directly in dollars. As indicated in   _
 Chapter  2, these values might come from maintenance of habitats or genetic
 diversity.  If you can link these values to services that are readily acquainted
 with human  activity, they may be more easily monetized.  For example,
 damage  to a fish nursery may ultimately show up in a decrement to sport
 fishing or commercial fisheries.  In this case, travel cost techniques could be
 used to measure the monetary value of damages to the sport fishery.  Changes
 in productivity of the commercial fishery could be measured in decreases in
 the dollar value of the harvest.  These measurements would not necessarily
 represent the entire value of damages to the life support function of the
  ecosystem, but they do capture  a portion of it. The enjoyment of such
  recreational opportunities and the commercial harvest of fish depend on
  maintaining the integrity of the ecosystem, but do not necessarily represent the
  entire value of preserving that ecosystem.

         Monetizing the recreational, cultural and aesthetic values of ecological
  resources may all require different approaches.  For instance, EPA identified
                                      22

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  dioxin contamination of salmon as a contributor to the loss of spiritual health
  in some Native American tribes that no longer could use the fish in religious
  ceremonies.  To determine the monetary value of the cultural benefits
  associated with reducing dioxin contamination, EPA evaluated the monetary
  value of previously negotiated packages used to compensate Native Americans
  for limitations on tribal fishing rights.  These values formed the basis for an
  estimate of monetized cultural values resulting from regulation.

        Likewise, the Grand Canyon example mentioned in chapter 2
  exemplifies the measurement of the monetary value of aesthetics through
  contingent valuation.  The use of scrubbers was expected to improve visibility
  at the Grand Canyon.  The worth of improved visibility was measured by
 asking people about their willingness to pay for it.  Such surveys allowed the
 direct comparison of the environmental benefits of installing scirubbers to the
 cost of the requirement.                                    j
                                                           i
       To develop reasonable estimates for the value of ecological resources,
 ensure that where possible, risk assessments provide information that can be'
 used in the development of economic analyses. This is necessary regardless of
 the approach taken in considering values. As noted in chapter 3, when
 selecting endpoints for an ecological risk assessment, one characteristic to
 consider is whether the endpoints assist in developing all phases, of the
 assessment. An important aspect of this characteristic, but  not the driving
 factor in endpoint selection, is the clarity with which the value of a resource
 can be described in the economic analysis (either qualitatively or
 quantitatively).  If carefully designed, an economic analysis caaprovide
 information to help you interpret the likely economic effects of a risk
 management decision.  Regardless  of whether a cost/benefit analysis is
 required, assessing  the costs and benefits of options helps inform decision-
 makers and the public about one aspect of the effects of a risk management
 decision.
                                                           I

       After all attempts to monetize values associated with endpoints are
 made,  the risk assessor should then describe qualitatively or with examples the
 types of additional values associated with those endpoints. Then, when all
relevant factors have been considered, it's time to make that risk management
decision.
                                   23

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                                Chapter 6

         Risk Decision-making:  How Do You Make Up Your Mind?

       This chapter is not so much about what to do.  It is more about what to
consider in making ecological risk management decisions.

       No risk assessment will ever be perfect or provide total certainty.  ;
Rather, your job is to weigh alternatives and exercise judgment in selecting the
best risk management option. This may include balancing many conflicting
demands, such as timeliness vs. certainty, short-term cost vs. ultimate
effectiveness, immediate response to satisfy the public vs. long-term cost or
benefit, and possibly some fear about making the wrong decision or about
which business or environmental group may attack your decision.

       Here are some things to keep in mind as you ponder the information at
your disposal.

       Focus on endpoints.  When interpreting a risk assessment, focus on
the assessment endpoints and their values.  They are the foundation on which
decisions are built.

       Assessment endpoints should be supported by a clear explanation of
their relationship to the site or situation being evaluated. Measurement
endpoints should be clearly linked to assessment endpoints.  If possible,  this
linkage should be characterized quantitatively, although available data often
permit only a qualitative description.  For example, in a case where game fish
and fish-eating birds are the assessment endpoints and toxicity to aquatic ;
invertebrates is the measurement endpoint, the ecological risk  assessment
should carefully describe the invertebrates' role and importance in the food
web.  Their functions probably will not be obvious to most people.

        Consider uncertainty.  Understand the limitations of the assessment
 and EPA's overall level of confidence in it.  For example, what kinds of '
 information are missing, and how important are they to the estimates of risk?
 Of the existing data gaps, which ones are likely to receive attention from
 groups outside EPA?  Add the essential  human element to the decision:
 Weigh the numbers against agency policy and your professional judgment.
 Data are not a substitute for knowledge, and computer-generated figures are
 not beyond questioning.  And judgment  cannot completely replace data - if
 you're not comfortable making your decision with existing data, ask for
 clarification or more information on the areas you feel are lacking.      i
                                     24

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       Understand the risk, its magnitude and how much rijsk you are
willing to accept. You also should understand the severity of the risk
involved, and put it into proper perspective.  What is its extent: Is it a certain
and substantial threat, or borderline?  Is it a short- or long-term risk?  For
example, a 20 percent reduction of fish in a commercial fishery may not seem
critical at first glance.  Yet considering the levels of fish need**! to maintain
healthy populations in the long run, 20 percent may actually represent all of
the harvestable fish.
                                                           I
       An individual's perception of a risk will depend on whether he or she
benefits from the risk or bears  its burden  and cost. Sometime!} people come to
regard a risk as acceptable simply because they are familiar with it.  The term
"acceptable"  conjures up a variety of images.  Some regard it as "everything's
OK," while others think "things are mostly OK, and we're willing put up with
the things that aren't," and still others refuse to use the term at all, claiming
that there is no acceptable risk.
                                                           i

       EPA sometimes permits activities that produce substantial risks, but it
is critical to remember that these decisions are the result of tradeoffs between
risks and benefits, or between multiple risks.  Although theoretically possible,
it is usually impractical to reduce risks to truly negligible levels. Thus, a risk
associated with a particular action  should  never be considered negligible just
because the agency permits that action.

       EPA policy sometimes defines limits for assessing risks, to human
health, such as a one-in-a-million risk of cancer.  The "acceptable risks" of
ecological risk assessment are not  so obvious. One example of this blurred
view is the assessment factors ranging over several orders  of magnitude that
OPPTS applies to set "concern levels" for new chemicals.  These levels apply
to groups of  organisms and are based on available data.  If OPPTS predicts
that these concern levels would be equaled or exceeded, then adverse effects
are expected. However, there  is no guarantee that adverse effects will not
occur below  these concern levels.                            j

       Consider the ecological risks of the alternatives.  Synthetic
pyrethroids, used in growing cotton, provide one example of a tradeoff
between  risks.  This class of pesticides is  toxic to aquatic life, and in
concentrations expected under field conditions, is particularly tpxic  to aquatic
invertebrates. But the other pesticides that could be used in growing cotton
are not only  more toxic to  aquatic life, but toxic to birds and mammals as
well.  In this case, EPA chose  to allow the use of pyrethroids, but required
buffer zones  between cotton fields and water bodies to minimize the effects of
the compounds on fish.  The buffer zones are designed to reduce water
concentrations below levels acutely toxic to fish,  although fish probably suffer
                                    25

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indirect effects from the acute toxicity to aquatic invertebrates.  The much
lower use levels required to protect invertebrates would have destroyed the
usefulness of the pyrethroids to farmers. Therefore, EPA decided that the
risks to invertebrates were acceptable, given the economic benefits of these
pesticides to cotton growers.

       Consider, too, a contaminated wetland at a Superfund site.  If the
remedy is to re-engineer drainage patterns, excavate the wetland, and replace
it elsewhere, the changes may solve the immediate problem of contamination.
However, this  "solution" may come at great cost to resident wildlife, because
the success  rate for replicating wetland structure and function is quite low.
'Rather than completely destroying valuable habitat, it may be better to tolerate
some short-term effects to  wildlife and rely on natural processes such as
biodegradation, erosion and sedimentation to mitigate the contamination.

       Consider the balance between human health and ecological
concerns.   At present, techniques for human-health risk assessment are    ;
reasonably well-accepted, and public-health organizations track the incidence
of health effects such as cancer.  Unfortunately, since EPA regulates on the
basis of small risks, the data to support and validate these assessments may
leave something to be desired.  For example, embryo malformations often
result in miscarriage before a mother notices she is pregnant, and it is difficult
to detect a one-in-a-million excess cancer risk in a population of 100,000.  In
addition, wide-scale monitoring is seldom practical, and some effects do not
manifest themselves immediately. The result may be a precise, but not
accurate, risk estimate.                                                 '

       Many of the methods for  ecological risk assessment are still under
development.  On the other hand, field data are more often available, and  I
toxicity data are usually available for the organism of concern or a closely
related species. Sometimes adverse effects can be observed and even
associated with a specific site, activity or chemical (such as a fish kill
following a chemical spill).  In this case, assessments may produce accurate,
but not very precise, risk estimates.  Thus, while  a human-health assessment
may appear to be more quantitative or certain than an ecological assessment?
this is not necessarily the case.  And, as with human-health assessments, our
inability to  detect a predicted effect does not mean that it does  not occur.

       We  view risks to plants and  animals differently than risks to humans.
We require more evidence that ecological resources  are being adversely
affected before we take action, and  we generally evaluate individual risks to
humans and population risks to other organisms.   For example, if an action
were predicted to cause 200 excess  human cancers, we would not allow that
action to occur.  But if the action caused the same number of excess cancers in
                                     26

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birds or fish, we would ask whether the cancer would decrease the population
or reduce the economic or aesthetic value of the resource.  At Superfund sites,
we remediate for cancer risks lower than we can detect in the local human
population.  AWQC take a similar approach, with the intent of protecting the
aquatic community based on test data from a group of organisms rather than
on observed effects.
                                         Key Issues in Making
                                      Risk Management Decisions

                                       Adverse effects, exposure and
                                       risk
                                       Confidence in the data and
                                       assumptions
                                       Degree of consensus
                                       Risk management options
                                       Legal considerations
                                       Economic concerns, if applicable
       Finally, evaluate your
options. You should be
provided with a range of
options for addressing risk.
The possible tradeoffs of
costs and benefits involved
with each should be clearly
articulated.  Evaluate the key
aspects of each option (see
box), and acknowledge each
one's relation to the strengths
and limitations of the risk
assessment.  Don't forget the
"no action" alternative,
especially when EPA's "cure" might be worse than the "disease."
                                                          i
       After you've made your risk management decision, it's time to tell
people about it. Start in your own agency by documenting your results.
Justify your decision and describe how you reached it. Explain which data
were most important and how affected parties' concerns were factored into the
decision.  This information will provide institutional memory and help for
future risk managers in your program. As the agency records  more decisions
and precedents, perhaps it will become easier to make risk management
decisions in the future.

       Then it's time to tell the public — those who will be affected the most
by the  decision.                                            !
                                   27

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                                Chapter 7

                Communicating Risk:  How Do You Explain
                  A Risk Management Decision to Others?

       One of the most challenging aspects you may face as a risk manager is
justifying risk management decisions.  Risk assessors, senior managers,
environmental groups, industry and the public alike may question your
decision.  Involving them in earlier phases of your decision-making process
helps avoid problems at this  stage and facilitates effective communication of
your decisions.
       The particular style of
risk communication you
choose depends on the
complexity of the information
and the focus and
sophistication of your
audience. The
recommendations below, as
well as EPA's "Seven
Cardinal Rules of Risk
Communication" (see box),
should help you organize and
improve your communication.
These principles apply when
talking with anyone, at any
level, and the term  "public"
is used here to represent all
groups.

       A.    Tailor Risk
             Communication
             to Your
             Audience
EPA's Seven Cardinal Rules
  of Risk Communication

  Plan carefully and evaluate the
  success of your efforts.

  Coordinate and collaborate with
  other credible sources.

  Accept and involve the public as
  a legitimate parmer.

  Listen to the public's specific
  concerns*
         _,                      t
  Be honest, frank and open,
                               t
  Speak clearly and with
  compassion.

  Meet the needs of the media.
       As a risk communicator, you are responsible for increasing public
knowledge about ecological risks (education) and increasing public interest in
ecological issues (promotion).  Before trying to communicate risk, understand
the perceptions, biases and knowledge of your audience.  Knowing how people
view the problems confronting them will help you develop an effective
message.
                                   28

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       Norton (1989) identified three human perspectives, or paradigms, on
the environment in the United States: exploitation, conservation and
preservation. Exploitationists are the most anthropocentric.  They view the
natural world as consumable resources  to be used to achieve human pursuits.
The value of resources is normally measured economically.  Conservationists
also are anthropocentric, but they acknowledge the less tangible benefits of
ecological resources, such as non-consumptive uses like recreation and
aesthetic values.  Conservationism incorporates long-term planning and
management of ecological resources  to ensure that these values are maintained.
Preservationists want to protect the natural world because of its intrinsic value.
They feel that preserving ecological  resources is important for reasons other
than benefits to humans.                                    j

       It helps to determine which paradigm dominates the group with which
you are communicating. Normally,  though, all three perspectives can be
addressed for any environmental issue.  Your audience often will include
individuals that represent all three paradigms, and one individual can  operate
under different paradigms, depending on the nature of the risks you describe.
In any case, it is important to include all three  paradigms in your risk
communication plan so you can emphasize those issues most appropriate to
your audience.  For example, when  communicating the risk of cutting down
tropical rain forests, you might emphasize to exploitationists the expected
economic losses from excess erosion, damaged equipment and foreign
government intervention; to conservationists, the loss of current and future
medicinal benefits from undiscovered or depleted tropical plants; and  to
preservationists, the loss of biodiversity.
       B.     Describe the Ecological Resources at Risk and
              Communicate Their Value
       In contrast to human health issues,  documenting risk to ecological
 systems may be difficult and uninteresting  to many of the public.  Ecological
 resources at risk, whether individuals, species, populations, communities,
 ecosystems or biospheres, can be difficult  to define.  The type and
 characteristics of ecological resources at risk will dictate the legal mandates,
 regulatory options and approach most appropriate to your communication.
                                                           i
       Legal  mandates provide  the most straightforward means of defining
 ecological risk.  The ESA is among the strongest laws available, but is limited
 to species on  the edge of extinction.  However, the ESA may also be used to
 argue effectively for protecting  communities of organisms upon which the
 threatened or endangered species depends.  Other legal mandates provide the
 basis for protecting communities or ecosystems.  For instance, the Clean
                                     29

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Water Act requires protecting the "chemical, physical and biological integrity
of the Nation's waters."

       You often must incorporate the values of the particular resource that
contribute to human health, economic development and quality of life.  For
example,  the values of maintaining viable communities of macroinvertebrates
may best be explained to sport fishermen by emphasizing the              ;
macroinvertebrate community's importance to a sport fishery.

       Whatever the value of an ecological resource and how  it is described, it
is important that you explain both the costs of protecting, as well as the costs
of failing to protect, the resource. Depending on the nature of the stressor,
you may have to discuss short- and long-term benefits.                    ;

       D. Describe the Risk

       The public is concerned about risk.  Sometimes their concern is highest
where risk is lowest. Likewise, they may have little concern about risks you
believe are  significant.  Much of this perception problem stems from poor risk
communication.  To improve it, discuss issues  concerning the sources and
causes of risk, the ecological resources at risk, and the seriousness of potential
effects.

       When describing the sources and causes of risk from a human activity
or stressor, include the type  of stressor and the characteristics that make the
stressor cause adverse ecological effects.  Discuss how effects and exposure
occur, the amount of exposure occurring, and how the stressor moves  through
and persists in the environment.  If there  are multiple sources of the stressor,
describe what they are and their relative contributions.  Finally, include a
description  of possible forces contributing to the problem (social, cultural,
economic, natural).

        Place the ecological resources at risk within the broader context of the
ecosystem.  Discussions that focus narrowly on specific risk assessment
endpoints may not clearly represent all important issues or ecological resources
at risk.  Broaden the discussion to explain the relationships among organisms
in ecosystems that must be protected to ensure protection of the endpoint of
concern.

        Most public attention will be directed toward the seriousness of
potential effects.  Your descriptions should include the extent (local, regional,
national, international) and seriousness of adverse effects.  Include the duration
of the effects and the persistence of the stressor.   Describe when the effects
may occur, or how they are occurring, and who will be most affected. Keep


                                     30

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 in mind, too, that risk is relative. A local risk, such as a naturally confined
 Superfund site, may appear insignificant from a national perspective, but
 would be the primary concern of local residents. Yet global warming,
 considered a serious environmental risk, may engender little concern at the
 local level.

       Your risk management decisions are based to a significant degree on
 how the risk has been characterized.  Lay out for the public the same rationale
 used to make your decision.   Describe the uncertainties that make the decision
 difficult. Address  the likelihood that adverse effects will happen.

       E.    Discuss Options for Reducing Risks           i

       Public involvement and commitment are critical in  determining options
 for reducing ecological risk.   Discuss the different methods that may be used
 to control risks, such as  combinations of "command-and-control" and market-
 based  incentives, and voluntary compliance through education and outreach.
 Acknowledge that environmental risks can come from many sources, so
 placing responsibility for all risk on one contributor will not necessarily result
 in effective risk-reduction strategies.  Defining the source of particular
 stressors will help to define which entities should take primary responsibility
 for reducing risk, and all should participate in generating workable plans.
 Responsibility for risk reduction must be shared by federal, state and local
 governments; by industry and business; and  by the public.

       F. Work With the Media
                                                          I
       The media are the most widely used sources of environmental
 information.  Open communication with the  media, by interview, press release
 or during public meetings, can be an effective avenue for communicating with
 the public. If used well, the media can facilitate risk communication.

       Select "sound bites" before meetings that convey your decisions in
 short, understandable messages.  Be open to media coverage, but time those
arrangements carefully so you will not be caught unprepared.  Think again
about the three environmental  paradigms discussed earlier,  and try to frame
meaningful and understandable messages for the public that address something
of value within each paradigm.
                                   31

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                               Chapter 8

               Conclusions: Where Do We Go From Here?            ;

      The evolution of ecological risk assessment at EPA demands more than
ever that risk managers, risk assessors and the public work closely to make
better and more informed risk management decisions.  At the same time, many
areas in ecological risk decision-making need more research:  Open
communication between risk assessors and risk managers will help pinpoint
and prioritize those areas.
                                                                    t
      Risk decisions are difficult and we have much to consider in making
them. Ecological resources can be lost when they are  contaminated, wasted,
misused and overused.  Humans have the potential to destroy their own life
support system or to facilitate a sustainable, healthy  environment.  Our
decisions will help determine which path we follow.

       The purpose of this document was to provide basic information and
tools to help make more informed decisions involving  ecological risk.  For
more information, a list of suggested readings follows  the references.

       As we at EPA record and learn from our decisions, risk assessments
and risk management will improve.  We can help establish a body of
knowledge about risk decisions in EPA by documenting our decisions,
including rationale and evidence, so they can be incorporated into  an agency-
wide data base.  We can  ensure that appropriate assessments and monitoring
are used to determine whether we accomplished what  we set out to do, in the
manner in which we intended. After all,
                We don't inherit the earth from our ancestors.
                      We borrow it from our children.
                                                           Anonymous
                                    32

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 Ciba-Geigy Corp. vs. U.S. EPA.
        88-4361.  June 2, 1989.
                                       References
1989. U.S. Court of Appeals Fifth Circuit.  No.
 Colborn, T., F.S. vom Saal and A.M. Soto.  1993.  Developmental Effects of
       Endocrine-Disrupting Chemicals in Wildlife and Humans.  In Environmental
       Health Perspectives.  Journal of the National Institute of Environmental Health
       Sciences.  Vol. 101,  No. 5.  Pp. 359-458.  October 1993.

 Erlich, Paul and Anne. 1981.  Extinction:  The Causes and Consequences of the
       Disappearance of Species. Random House, New York.

 Fox, G.   1992.  Epidemiological and pathological evidence of contaminant-induced
       alterations in sexual development in free-living wildlife.  In:  Chemically
       induced alterations in sexual and functional development: the wildlife/human
       connection.  T. Colborn and  C. Clement, eds. Princeton Scientific Publishing
       Princeton, NJ.  Pp. 147-158.
                                                                i
 Guillette, LJ. and T.S. Gross.  1994. Pesticide induction of developmental
       abnormalities of the reproductive system of alligators (Alligator
       mississippiensis) and turtles (Trachemys scriptd). Abstract from Estrogens in
       the Environment III:  Global  Health Implications.  National Institute of
       Environmental Health Sciences, Washington, DC.  Jan.  9, 1994.
                              :                                  I
 Harms, Valerie.  1994. The National Audubon Society Almanac  of the Environment -
       The Ecology of Everyday Life. G.P Putnam's Sons,  New  York.

 Hileman, Bette.  1994. Environmental Estrogens Linked to Reproductive
       Abnormalities, Cancer.   Chemical and Engineering News. Jan. 31  1994  Pp
       19-23.

Johnson,  K.N., J.F. Franklin, J.W. Thomas,  J. Gordon.  1991.   Alternatives for
       Management of Late Successional Forests of the Pacific Northwest.  A report
       to the U.S. House of Representatives.  Oct. 8, 1991.

National  Research Council.  1983. Risk Assessment In the Federal Government:
       Managing the Process. National Research Council, National Academy Press,
       Washington, DC.
                                                                i

Norton, Bryan G.  1989.  Intergenerational Equity and Environmental Decisions:  A
       Model Using Rawls' Veil of Ignorance.  Ecological Economics. Vol.  1, pp
       137-159.                                                  i         W
                                         33

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Raloff, Janet.  1994.  "The Gender Benders."  Science News.  Jan. 8, 1994.  Vol.;
       145, pp. 24-27.

SuterJl, Glenn W.,ed.  1993.  Ecological Risk Assessment.  Lewis Publishers.
       Chelsea, MI.  538pp.

US Environmental Protection Agency.  1990. Reducing Risk:  Setting Priorities and
       Strategies for Environmental Protection. The Report of The Science Advisory
       Board's Relative Risk Reduction Strategies Committee to William K. Reilly,
       Administrator, p. 9.

US Environmental Protection Agency.  1992a. Peer Review Workshop Report on a
       Framework for Ecological Risk Assessment. EPA/630/R-92/002, Risk
       Assessment Forum, Washington,  DC.

U.S. Environmental Protection Agency.  1992b. Framework for Ecological Risk
       Assessment. EPA/630/R-92/001.

U S. Environmental Protection Agency.  1993a. OPP's Ecological Risk Manager
       Survey. Conducted by Anne Barton and Ingrid Sunzenauer, Environmental
       Fate and Effects Division, Office of Pesticide Programs.  Aug. 3, 1993.

U.S. Environmental Protection Agency. 1993b.  Protecting  Habitats and Ecosystems:
       An EPA Strategy.  Draft report by the Habitat Cluster.  Jan. 14, 1993.

U.S. Environmental  Protection Agency. 1993c.  Ecosystem Protection.  Draft report
       for the U.S. EPA's National Performance Review. Aug. 6,  1993.

 US Environmental  Protection Agency.  1994a.  Toward a Place-driven Approach:
       The Edgewater Consensus on an EPA Strategy for Ecosystem Protection.
       Draft report from Robert Perciasepe, David Gardiner and Jonathan Cannon to
       Carol  Browner.  March 16, 1994.

 U.S. Environmental Protection Agency.  1994b.  Managing Ecological Risks at EPA:
       Issues and Recommendations for Progress.  By Michael Troyer and Michael
       Brody. EPA/600/R-94/183.

 Wilson, Edward O.  1992. The Diversity of Life.  W.W. Norton and Co., Inc., New
       York.
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                                   Suggested Readings

 Abbey, Edward. 1968.  Desert Solitaire. Random House, New York.
              A season in desert wilderness.

 Carson, Rachel.  1962.  Silent Spring. Fawcett Crest, New York.
              DDT and its effects on other organisms.  Some people think this is the
              book that got it all started.

 Leopold, Aldo.  1949. A Sand County Almanac.  Oxford University Press.
              The origin of thinking like a mountain.                i

 MaM, A.W. and M.W. Slimak.  1990.  The Role of Ecological Risk Assessment in
       Decision Making.  In Ecological Risks - Perspectives from Poland and the
       U.S. W. Gradzinski, E.B. Cowling and A.I. Breymeyer, eds. National
       Academy of Science, Washington, DC. Pp. 77-87.

 Real, Leslie A. and James H. Brown, eds.  1991. Foundations of Ecology: Classic
       Papers with Commentaries.  University of Chicago Press.
              A variety of seminal technical readings in ecology.
                                                                 i
 Suter II, Glenn W.  1990. Endpoints for Regional Ecological Risk Assessments.
       Environ. Manage.  14:9-23.
                                              i
Travis, C.C. and B.P. Blaylock. 1992.  Setting Priorities for Environmental Policy.
       Environ. Sci. Technol.  26(2):215.

Wilson, Edward O., ed., and Frances M. Peter, assoc. ed.  1988.  Biodiversity.
       National Academy Press, Washington.
             A varied and accessible collection of short essays on biodiversity. A
             companion video is also available.
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                                                                                          I
             The Agency Ecological Risk Management Communication Group
Anne Barton, Director, Environmental
Fate and Effects Division, OPP/OPPTS
      Anthony Maciorowski,
      OPP/OPPTS
      Ingrid Sunzenauer, OPP/OPPTS
      Mary Powell, OPP/OPPTS
      Candy Brassard, OPP/OPPTS

Margaret Stasikowski, Director, Health
and Ecological Criteria Division, OST/OW
      Suzanne Marcy, OST/OW

Wendy Cleland-Hamnett, Deputy Director,
Office of Regulatory Management and
Evaluation, OPPE
       Angela Nugent, ORME/OPPE
       Michael Brody, ORME/OPPE

David Davies, Deputy Director, Office of
Wetlands, Oceans and Watersheds, OW

Jay Benforado, Deputy Director, Office of
 Science, Planning, and Regulatory
 Evaluation, ORD
       Anne Sergeant, OHEA/ORD
       Sue Norton, OHEA/ORD
       Michael Troyer, ORD

 Dorothy Patton, Director, Risk Assessment
 Forum,  ORD
       Bill van der Shalie, RAF/ORD

 Joe Cotruvo, Director, Chemical Screening
 and Risk Assessment Division,
 OPPT/OPPTS
        Don Rodier, OPPT/OPPTS
        Lynne Blake-Hedges,
        OPPT/OPPTS
Larry Reed, Director, Hazardous Site
Evaluation Division, OERR/OSWER
      Jeff Langholz, OERR/HSED
      Sandra Lee, OERR

John Bachman, Associate Director,
Science/Policy and New Program
Initiatives, OAQPS/OAR

Joe Merenda, Director, Environmental
Health and Review Division,
OPPT/OPPTS

Mike Slimak, Deputy Director, Office of
Environmental Processes and Effects
Research, ORD

Pat Cirone, Region X
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