United States
   '•nmentai ;

  Setting Environmental Priorities:
  The Debate About Risk

United States
Environmental Protection Agency
Office of Communications
and Public Affairs
                                            From the Editor
    William K. Reilly

    Lew Crampton
    Associate Administrator for
    Communications and Public Affairs

    Charles Osolin
    Director of Publications
    John Heritage
    Karen Flagstad
    Associate Editor
    Ruth Barker
    Assistant Editor

    Jack Lewis
    Assistant Editor

    Nancy Starnes
    Assistant Editor

    Douglass Lea
    Contributing Editor

    Marilyn Rogers
    Circulation Manager
    Design Credits
    Ron Farrah
    James R. Ingram
    Robert Flanagan
    Fronl Cover: Environmental inspiration.
    Phoio by David Falconer for Folio, Jnc.
   Should Congress and EPA rely more on science in setting the nation's
   environmental priorities? Specifically, should they use comparative risk
analysis, assessing and comparing the risks between different problems, as
the yardstick? And, do we know enough? Is the science adequate?
  Last fall, EPA Administrator William K. Reilly used the occasion of the
public release of an important and provocative report to launch a national
debate on these questions. The report was prepared at Reilly's request by
EPA's Science Advisory Board. Among other things, the report
recommended applying comparative risk analysis to sort out environmental
problems and reevaluate their importance relative to each other.
  The editors have prepared this issue of EPA Journal to extend the debate.
We invited contributions from some senators and congressmen who have
authority over environmental legislation  and  appropriations; we asked
scientists from universities and from government; and we solicited the
views of knowledgeable representatives from industry and from
environmental  organizations. We were impressed by the thoughtfulness and
variety in the answers we received, whether they were skeptical or
supportive of risk-based decision making.
  To provide a historical context for the  debate, we asked Al Aim, who has
been involved with the Agency from the beginning, to do a piece, and we
asked EPA Deputy Administrator Henry Habicht to  explain what the
Agency is doing now to strengthen its ability to make sounder,
science-based environmental decisions. Other articles spell out the Science
Advisory Board's recommendations regarding a risk-based environmental
action philosophy and describe how the  public's environmental agenda is
expanding, as new problems are added to old.
  You, the reader, may notice something else: EPA Journal is changing.
This issue includes a book review. A new section Habitat, will feature
sometimes poetic, sometimes humorous segments from the works of great
environmental writers. Featuring EPA contains (in this issue) an article on
how Russian and EPA scientists worked  together to measure Chernobyl's
effects in the Baltic Sea. Last issue we introduced Newsline, which
gives you glimpses of EPA actions. The issue before, we redesigned
the table of contents to make it more inviting and narrowed the
outer margins to provide more "white space" on the pages. You can expect
more changes in future issues, such as an occasional profile of a famous
conservationist and a Focus section which will explain key environmental
problems for students and their teachers. We are excited about the idea of
fashioning a better, more interesting, more approachable magazine, and we
welcome your  comments as the process unfolds.
  EPA journal is printed on recycled paper.
 EPA is charged by Congress to protect the nation's land, air, and water systems. Under a mandate of national environmental laws, the Agency strives to
 formulate and implement actions which lead to a compatible balance between human activities and the ability of natural systems to support and nurture life.
   EPA journal is published by  the U.S. Environmental Protection Agency. The Administrator of EPA  has determined that the publication of this periodical is
 necessary in the transaction of the public business required by law of this agency. Use of funds for printing this periodical has been approved by the Director of
 the Office of Management and Budget. Views expressed by authors do not necessarily reflect EPA policy. No permission necessary to reproduce contents
 except copyrighted photos and other materials.
   Contributions and inquiries should be addressed to the Editor, EPA Journal (A-107), Waterside Mall, 401 M Street, SW., Washington, D.C. 20460

          NUMBER 2
                                                                           MARCH/APRIL 1991
  Why I Propose
  a National Debate
  on Risk
     by William K. Reilly
  What Raised the
      by Raymond Loehr
  Why We Didn't Use
  "Risk" Before
             by Al Aim

Should  We Set
Priorities Based on
Risk Analysis?
(Daniel  Patrick
Moynihan, Jonathan
Lash, J.  Roy Rowland,
Lawrie Mott, Joseph I.
Lieberman, Bernard D.
Goldstein, Bob
Traxler, Peter F.
Guerrero, Steve
Symms, Nicholas L.
Reding, Lee M.
Thomas, Don Ritter,
and Mark Sagoff)
Do We Know Enough
to Take a Risk-Based
(D. Warner North,
Paul Deisler, Frank
Mirer,  Gilbert S.
Omenn, Paul J. Lioy,
William Cooper,
Stanley Auerbach,
Mark A. Harwell, John
D. Graham, Nancy
Kim, Adam M.  Finkel,
and Thomas A. Burke)
What the Public
by Thomas A.W. MiJJer
  and Edward B. Keller

The Road to
   fay F. Henry Habicht

A Dissenting Voice
  by David Durenberger

News from EPA

Cross Currents—
How Does Your
Garden Grow?

Habitat—A Lesson
from The Immense

Featuring EPA—On
Chernobyl's Trail
        by Miles Kahn

On the Move—New
Names in Key Agency
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Why  I  Propose
a   National  Debate  on  Risk
 by William K. Reilly
 In Shakespeare's Troiius and
 Cressida, the Greek hero Ulysses
 is heard to muse:
   The heavens themselves, the
     planets, and this center,
   Observe degree, priority, and place,
   Insisture, course, proportion,
     season, form,
   Office, and custom, in all line
     of order.

  Ulysses would find it hard to work
at EPA—or, indeed, anywhere in the
United States—during the final
decade of the 20th century. Today,
setting priorities is difficult under the
best of circumstances, even at the
relatively coherent level of the
individual household or local
community. At EPA, the speed of
change and the complexity of issues
generates such severe turbulence that
simply keeping a day's schedule "in
all line of order" is something of a
  Setting environmental priorities for
the whole nation and bringing our
Agency's resources into alignment
with those priorities are supremely
daunting tasks. It is only a slight
exaggeration to say they demand  the
rigorous thinking of a mathematician,
the resolute discipline of a Zen
master, and the extended vision of an
  In  1991, EPA has a budget of more
than $6 billion and employs about
17,000 scientists, lawyers, and other
professionals and administrative
personnel—a 310 percent increase
from the 5,500-person workforce that
formed the Agency in 1970. These
employees, located  in the Agency's
Washington headquarters, 10 regional
offices, and 56 research laboratories,
(ReilJy is Administrator of EPA.)
work under the authority of a dozen
major environmental laws and some
100 other statutes, all of them
enacted since 1970. EPA employees,
moreover, are responsible for writing,
refining, and enforcing 9,000
regulations and for responding to an
annual flood of tens of thousands of
letters from Members  of Congress,
other government officials, and
taxpayers. Imposing rules of  logic,
efficiency, and effectiveness on this
incipient chaos requires a keen sense
of priorities.
  This lesson was reinforced in my
mind  shortly after my EPA
appointment was announced, when I
made a memorable courtesy call on a
leading member of the Senate
Environment and Public Works
Committee, which would soon be
considering my confirmation. "Above
all," insisted New York's Senator
Daniel Patrick Moynihan, "above
all ... do not allow your agency to
become transported by middle-class
enthusiasms." His meaning, of
course, was unmistakable: "Pay
attention to science; don't be swayed
by the passions of the moment."
  The Senator's advice meshed
nicely with my own thinking and
that of my immediate predecessor.
Thanks in part to Lee Thomas'
pioneering work, I came to EPA
convinced that we need to change
our approach to environmental
problems. Although we have
achieved important victories over the
past two decades, we have developed
our environmental policies
piecemeal, with each  problem
addressed separately and without
sufficient reference to other problems
or to overall effects, risks, and costs.
  Each time a new issue appeared on
the radar screen of public concern,
we would unleash an arsenal of
control measures in a style
             Fatal smog: In 1948, industrial
                  smoke from the Donora,
            Pennsylvania, zinc works of the
                 American Steel and Wire
              Company killed more than 20
                people. This early incident
              focused the nation's attention
                     on the hazards of air
             pollution—beginning a pattern
                  in which environmental
                 priorities have been set in
                     response to disasters.
reminiscent of the old "space
invaders" video game. In the late
1960s, for example, we saw air
pollution and we enacted ambitious
legislation designed to scrub the air.
At the same time, we also became
aware of water problems, so we tried
to solve them with an equally
ambitious water act. Next, we saw
toxic  chemicals endangering health,
and we passed a sweeping  law to
control toxic substances. And so it
went  through the 1970s and 1980s,
with drinking water, radiation,
hazardous waste, pesticides, indoor
pollution, medical wastes, and many
other  problems. Each deserved
attention, to be sure, but each was
dealt  with separately, in isolation
from all the others.
  The consequence of this approach
is obvious to all our employees: For
20 years we have established goals  on
a pollutant-by-pollutant and
medium-by-medium basis without
adequately considering broader
environmental quality objectives.
Rarely have we evaluated the relative
importance of pollutants or
environmental media—air, land, and
water. Nor did we assess the
combined impacts on  whole

                         EPA JOURNAL

Wide VVorJd photo.
ecosystems and human health. Given
the scatter-shot evolution of the
Agency and its missions, we were
seldom encouraged to look at the
total loadings of pollutants deposited
through different media from  separate
routes of exposure at various
locations. We have seldom if ever
been directed by law to seek out the
best opportunities to reduce
environmental risks,  in toto, or to
employ the most efficient,
cost-effective procedures.
  Such fragmentation has a cost. EPA
is simultaneously pulled in many
directions by Congress, other federal
agencies, other levels of government,
the regulated community,
constituency groups,  the courts, the
public, and the press. We answer to
many taskmasters. To take just one
example of the complexity of  our
work, approximately  100
congressional committees and
subcommittees lay claim to a piece of
the environmental policy pie.  Many
problems, such as local land-use
decisions, are not in our jurisdiction,
yet we often find citizens hold us
responsible for solving them. When
the press zeroes in on a "pollutant of
the week," it rarely considers  the

pollutant's importance relative to
other environmental problems—or to
any of a number of competing social
issues, for that matter.
  Crisis management is certainly not
unique to the environmental arena.
 We have seldom if ever
 been directed by law to seek
 out the  best opportunities to
 reduce  environmental risks,
 in toto,  or to employ the
 most efficient, cost-effective
Nevertheless, since we deal with the
public's health and safety every day, I
believe it is necessary to step back
occasionally and take a broader view.
Looking ahead to the environmental
problems already looming in the 21st
century, I think the time has come to
find a better way of setting
environmental priorities. In short, we
need to find a way of bringing
Senator Moynihan's advice about the
critical importance of sound science
into the center of our
decision-making processes.
  To the extent allowed by law,
sound science can help us
establish priorities and allocate
resources on the basis of risk.
Obviously, many factors go into
shaping priorities—the values and
perceptions of the American  people,
the constraints of the economy, the
culture of governance—but hard
science remains our most reliable
compass in a turbulent sea of
environmental concerns. Science can
lend a measure of coherence,
predictability, authority, order, and
integrity to the often costly and
controversial  decisions that must be
  Using risk as a common
denominator creates a measurement
that lets us distinguish the
environmental equivalents of heart
attacks from indigestion, the  broken
bones from bruises.  Despite
uncertainties  and controversies
hovering around the evaluation of
hazards, comparative risk assessment
already serves as an excellent
guidepost for indicating the most

                         For 20 years we have established goals on a
                         pollutant-by-pollutant and medium-by-medium basis
                         without adequately considering broader
                         environmental quality objectives.
promising road to follow, for
targeting our limited resources, and
for mobilizing and deploying
expertise in an efficient and rational
  Five years ago, Lee Thomas first
officially recognized the  problem of
setting priorities by instructing EPA's
scientists and managers to examine
our assignments and then try to rank
environmental problems on the basis
of risk. The result of this exercise was
a brave and visionary report
published in 1987 under the title:
Un/inished Business: A Comparative
Assessment of Environmental
  After ranking environmental
problems on the basis of risk, the
report revealed that expert and public
opinions about the seriousness of
many environmental problems
diverge markedly. As Unfinished
Business put it, "EPA's priorities
appear more closely aligned with
public opinion than with estimated
risk." Not surprisingly, our  laws are a
better reflection of constituent
opinion than of scientific judgment.
The inescapable conclusion: We need
to improve the translation of
scientific knowledge into the
vernacular of politics and public
opinion, to make  rational risk
assessment a part of every citizen's
common sense.
  In one of my first actions as EPA
Administrator, I asked the Agency's
Science Advisory Board (SAB)—a
distinguished panel of independent
scientists, engineers, and other
technical experts—to review
Un/inished Business, assess its
rankings by applying the best
technical and scientific knowledge
available, and suggest ways to
improve the process of identifying,
assessing, and comparing risks. I also
asked the board to find strategies that
would be particularly effective for
attacking specific problems or for
mitigating many  problems at the
same time.
  The fruits of the SAB study-
chaired by Dr. Ray Loehr of
the University of Texas and Jonathan
Lash, former Secretary of Vermont's
Natural Resources Agency and now
director of the Environmental Law
Center at Vermont Law School—were
published in September 1990. The
board's report, Reducing Risk: Setting
Priorities and Strategies /or
Environmental Protection,
significantly advances the
environmental debate by comparing
disparate environmental problems
according to degree of risk and
spelling out the fundamental
principles for developing broader,
more integrated, and more carefully
crafted environmental policies.
  The most  essential
recommendation in Reducing Risk
proclaims, in no uncertain terms, that
EPA and the nation must locate  and
target the most promising
opportunities for reducing the most
serious risks to human health and
welfare and  to the environment. I
believe that  our response to this
recommendation is pivotal to the
success of all our efforts at
environmental protection.
  Chosen primarily on the basis of
the overall degree of public exposure
to known toxic agents, the  human
health risks  highlighted in  the report
are: ambient air pollution; exposure
of industrial and agricultural workers
to dangerous chemicals; indoor air
pollution, including radon; and
contamination of drinking water,
particularly  by lead. The recent
reauthorization  and strengthening of
the Clean Air Act reflects this
ordering of priorities. Also
compatible with the underlying
principle of this listing is EPA's
Pollution Prevention Strategy, which
presents a blueprint for a
comprehensive, voluntary program of
pollution prevention across the
country. One important goal of this
strategy is the reduction of emissions
of 17 especially troublesome toxic
chemicals by 33 percent by the end
of 1992 and 50 percent by the end of
  Reducing Risk also identifies
high-risk ecological problems, chosen
chiefly on the basis of their
geographic scope and the time
necessary to reverse negative impacts:
alteration and destruction of habitat;
extinction of species and loss  of
genetic diversity; depletion of
stratospheric ozone; and changes in
the global climate. The report further
recommends that we address
ecological risks with the same level
of effort that we have devoted in the
past to human health risks. This
recommendation recognizes the
intimate  relationship between vital
and productive natural ecosystems
and the ultimate well-being of people
and their only habitat.
  In April of this year, two different
reports underscored the SAB's focus
on ecological relationship. First, a
NASA study showed that ozone loss
over the  United States since 1978 has
amounted to almost 5 percent, nearly
twice what we thought just a few
months ago when the  community of
nations negotiated amendments to
the Montreal Protocol. EPA estimates
this could result in an additional
200,000 American deaths from skin
cancer over the next 50 years—a
fatality estimate 21 times higher than
previously forecast. (These are
estimates based on models and could
vary plus or minus 25 percent.)
Second,  in an EPA-funded study of
global climate change, the National
Academy of Sciences  said the
possibility of global warming (by as
much as nine degrees Fahrenheit)
"poses a potential threat sufficient to
merit prompt responses," including
U.S. participation in international
programs to slow population growth,
development of safer and more
efficient  transportation and energy
systems, reforestation, elimination of
chlorofluorocarbons (which are also
                                                                                                 EPA JOURNAL

  the prime culprit in ozone depletion),
  and public education for
  conservation and recycling programs.
     Meanwhile, it is important to
  remember that both Unfinished
  Business and Reducing Risk assume
  that currently mandated programs
  will continue far into the future. EPA
  has no intention of relaxing the vigor
  with which we are enforcing
  environmental laws already on the
  books. In fact, in 1989, we set records
  in virtually every  category of
  enforcement—and then we broke
  them in 1990. So  we've established
  our bona fides.
     Nevertheless, the time has come to
  pay as much attention to how we
  spend our resources as to what we
  spend them on. The traditional
  approach to environmental
  regulations oriented toward specific
  technologies—as much as it has
  achieved, is no longer sufficient.
     The great complexity of our
environmental problems requires an
equivalent complexity in our
responses. Among the responses
already suggested in the SAB report
are increased research,  public
education and information
dissemination, technical assistance,
market incentives, and, above all, a
national mobilization to prevent the
creation of pollution in the first
  Our budget decisions already are
being guided by the risk-reduction
principles of EPA's  long-term
planning process. New programs,
such as our  strategy for cleaning up
the Great'Lakes region, involve
innovative efforts that cross
jurisdictional lines,  wipe out the
artificial boundaries that
compartmentalize the various media
of contamination, and integrate
enforcement mechanisms affecting
entire ecosystems.
  Changing  the way EPA does
business means moving science and
   Drawing by Weber; copyright! 1 989. The New Yorker Magazine. Inc.
information processing to the very
center of our enterprise. To
emphasize the importance I place on
this task, I try not to let a week pass
without discussing the implications
of the SAB report in one forum or
another. I speak to gatherings of
citizens and students, and the press. I
ask for hearings before Congress, I
enter into "constructive dialogues"
with environmental and industry
groups, and I consult with scientists
across the country.
  This issue of EPA Journal is yet
another contribution to EPA's efforts
to extend the dialogue and to provide
an airing of all  points of view; it
includes two forums, representing a
wide range of opinion  from key
observers, on two of the central
issues raised by the SAB report.
  I understand fully that any effort to
establish environmental priorities on
the basis of relative risk—in effect, to
rethink the environmental agenda for
the next century—is fraught with
contentiousness and difficulty. It
demands a tolerance for uncertainty,
a willingness to confront error and
learn from mistakes, a capacity to
adapt quickly to new information and
changing circumstances.
  But the potential  results more than
justify our efforts. If the long-term
course of environmental policy is to
gain currency,  if it is to be persuasive
in an enduring way, we at EPA must
ensure that our commitment  to the
environment is matched by the
scientific rigor  that  goes into the
choices we make and the decisions
we enforce. That, in a  nutshell, is the
challenge the Science Advisory Board
has laid at our—and the
nation's—doorstep. Q
"We've decided to express our concern for the environment by redecorating.

What  Raised  the  Issue?
 by Raymond  Loehr
                                      Early in 1989, Administrator Reilly
                                      asked the Science Advisory Board
                                    to review EPA's 1987 report,
                                    Unfinished Business: A Comparative
                                    Assessment of Environmental
                                    Problems, and to assess and compare
                                    different risks to human health and
                                    the environment in light of the most
                                    recent scientific data. He also asked
                                    that the board examine  strategies for
                                    reducing major risks and recommend
                                    improved methodologies for assessing
                                    and comparing risks and risk
                                    reduction options in the future. The
                                    board delivered a report to
                                    Administrator Reilly on September
                                    25, 1990; excerpts follow.
                              The Concept Of Risk
                              The fragmentary nature of U.S.
                              environmental policy has been
                              evident in three ways:
                              • In Laws. As different
                              environmental problems were
                              identified, usually because the
                              adverse effects were readily apparent,
                              new laws were passed to address
                              each new problem. However, the
                              tactics and goals of the different laws
                              were neither consistent nor
                              coordinated, even if the pollutants to
                              be controlled were the same.
                              • In Programs. EPA evolved an
                              administrative structure wherein each
(Loehr is Chair of the Science
Advisory Board and Professor of
Civil Engineering at the University of
                                        EPA's Science Advisory Board
The Congress, in 1978,
established the Science
Advisory Board to provide
independent scientific and
engineering advice to EPA and
to those committees of Congress
having responsibility for
environmental  matters. The EPA
Administrator appoints
members—currently, there are
60 who serve two-year terms.
Additionally, more than 250
scientists and engineers serve
the board as  consultants. The
eight committees of the board
conduct about  50 public
meetings and release 30 to 40
reports each  year. A 16-member
staff supports the activities of
the board.
  Shortly after  he took office,
Administrator Reilly asked the
                                                                       board to evaluate the findings of
                                                                       Unfinished Business, EPA's
                                                                       1987 report on environmental
                                                                       risk and to suggest innovative
                                                                       strategies for reducing sources
                                                                       of high environmental risk.
                                                                        In response, the board formed
                                                                       a Relative Risk Reduction
                                                                       Strategies Committee which, in
                                                                       turn, was divided into three
                                                                       subcommittees:  one each on
                                                                       human health, ecology and
                                                                       welfare, and strategic options.
                                                                       The 39 members of the
                                                                       committee were nationally
                                                                       recognized scientists, engineers,
                                                                       and managers with broad
                                                                       experience in environmental
                                                                       and health issues. In the course
                                                                       of their work, they held 12
                                                                       public meetings.
                                                                                             EPA JOURNAL

                                                            opyright Scott Taylor photo. Duke University Marine laboratory.
program was primarily responsible
for implementing specific laws.
Consequently, the efforts of the
different programs rarely were
coordinated, even if they were
attempting to control different
aspects of the same problem.
•  In Tools. The primary tools used  to
protect the environment have been
controls designed to capture
pollutants before they escape from
smokestacks, tailpipes, or sewer
outfalls, and technologies designed  to
clean up or  destroy pollutants after
they have been discharged into the
environment. These "end-of-pipe"
controls and remediation
technologies almost always have been
applied because of federal, state, or
local legal requirements.
  This fragmented approach to
protecting the environment will not
be as successful in the future as it has
been in the  past. The most obvious
controls already have been applied  to
the most obvious problems. Yet
complex and less obvious
environmental problems remain, and
the aggregate cost of controlling those
problems, one-by-one, is rising.
  Moreover, this country—and the
rest of the world—is facing emerging
environmental problems of
unprecedented scope. Population
growth and  industrial expansion
worldwide are straining global
  The environment is an interrelated
whole, and society's environmental
protection efforts should be
integrated as well. Integration means
that government agencies should
assess the range of environmental
problems, then target protective
efforts at the problems that seem to
be the most serious. It means that
                    When wetlands are altered or destroyed, so is critical
                    wildlife habitat. Wetland loss is rated a high-risk problem in
                    the Science Advisory Board report.
society should use all the
tools—regulatory and non-regulatory
alike—that are available to protect
the environment. It means that
controlling the end of the pipe where
pollutants enter  the environment, or
remediating problems caused by
pollutants after they have entered the
environment, is  not sufficient. Rather,
waste-generating activities have to be
modified to minimize the waste or to
prevent the waste from being
generated at all.  Most of all,
integration is critically important
because significant sources of
environmental degradation are
embedded  in typical day-to-day
personal and professional activities,
the cumulative effects of which can
become serious problems.
  One tool that can help foster the
evolution of an  integrated and
targeted national environmental
policy is the concept of
environmental risk. Each
environmental problem poses some
possibility of harm to human health,
the ecology, the economic system, or
the quality of human life. That  is.
each problem poses some
environmental risk. Risk assessment
is the process by which the form,
dimension, and characteristics of that
risk are estimated, and risk
management is the process by which
the risk is reduced.
  The concept of environmental risk,
together with its related terminology
and analytical methodologies, helps
people discuss disparate
environmental problems with a
common language. It allows many
environmental problems to be
measured and compared in common

terms, and it allows different risk
reduction options to be evaluated
from a common basis.
  Scientists have made some progress
in developing quantitative measures
for use in comparing different risks to
human health. Although current
ability to assess and quantify
ecological risks is not as well
developed, an increased capacity for
comparing different kinds  of risks
more systematically would help
determine which problems are most
serious and deserving of the most
urgent attention.
  An improved ability to compare
risks in common terms would have
another value as well: It would help
society choose more wisely among
the range of policy  options available
for reducing risks.
  There are heavy costs involved if
society fails to set environmental
priorities based on  risk.  If  finite
resources are expended on
lower-priority problems at the
expense of higher-priority  risks, then
society will face needlessly high
risks. If priorities are established
based on the greatest opportunities to
reduce risk, total risk will  be reduced
in a more efficient  way, lessening
threats to both public health and
local and global ecosystems.
          Workers adjust boom lines to
     protect the coastline between New
        Jersey and Staten Island, New
           York,  from a recent oil spill.
      Scientists ranked oil spills among
      relatively low-risk environmental
          problems, primarily because
      resulting ecological damages are
        usually  reversible. The public,
      however, sees such spills as more
                                        Wide World pholo.
                                                                                                        EPA JOURNAL

Problems In Ranking Risks

As long as there are large gaps in key
data sets, efforts to evaluate risk on a
consistent, rigorous basis or to define
optimum risk reduction strategies
necessarily will be incomplete, and
the results will be uncertain. For
example, data on human exposure
and on the toxicity of many
pollutants are seriously deficient.
  Moreover, great uncertainty often is
associated with the data that do exist.
Exposure and toxic-response models,
the numbers used to quantify risks,
and variations in individual
susceptibility to risks are often highly
uncertain. Without more and better
data, conclusions about relative risk
will be tenuous and will depend in
large measure on professional
  In addition to the lack of data,
methodological inadequacies also
impede the assessment and
comparison of risk. In particular, the
methodologies currently used to
estimate the benefits of risk reduction
activities are inadequate and
  An additional difficulty entailed in
any attempt to compare and rank
environmental risks is the inevitable
value judgments that must be made.
For example, are health risks posed
to the aged more or less serious than
health risks posed to infants?
Comparing the risks posed to human
populations with the risks posed to
ecosystems may be even more
difficult. It seems clear that
subjective values always will—and
should—influence the ranking of
relative environmental  risks, no
matter how sophisticated the
technical and analytical tools
The Extraordinary Value Of Natural
Natural ecosystems like forests,
wetlands, and oceans are
extraordinarily valuable. They
contain economically valuable
natural resources that feed, clothe,
and house the human race. They act
as sinks that, to a certain extent,
absorb and'neutralize the pollutants
There are heavy costs
involved if society fails to
set environmental priorities
based on risk.
generated by human activity.
Although natural ecosystems—and
the linkages among them—are not
completely understood, there is no
doubt that over time the quality of
human life declines as the quality of
natural ecosystems declines. Further,
they have an intrinsic, moral value
that must be measured in its own
terms and protected for its own sake.
  However, over the past 20 years
and especially over the past decade,
EPA has  considered the protection of
public health to be its primary
mission,  and it has been less
concerned about risks posed to
ecosystems. The Agency's relative
lack of concern reflects society's
views as  expressed in environmental
  Over the long term, ecological
degradation either directly or
indirectly degrades human health
and the economy. For example, as the
extent and quality of saltwater
estuaries decline, both human health
and local economies can suffer. As
    soils erode, forests, farmlands, and
    waterways can become less
    productive. And while the loss of
    species may not be noticed
    immediately, over time the decline in
    genetic diversity has implications for
    the future health of the human race.
    National efforts should recognize that
    human health and welfare ultimately
    rely on the life support systems and
    natural resources provided by healthy
—  Time, Space, and Risk
    Two aspects of potential
    environmental problems—i.e., their
    temporal and spatial
    dimensions—must be given
    considerable weight.
      The temporal dimension is the
    length of time over which the
    problem is caused, recognized, and
    mitigated. For some environmental
    problems it can be long. It may take
    decades of human activity to begin to
    change the global climate, and more
    decades may  pass before the effects of
    human activity on the global climate
    are clearly understood. Some
    pollutants can persist in the
    environment—and thus pose
    environmental risks—indefinitely.
    And it may take decades or even
    centuries before depleted species of
    wildlife recover from the loss of
      The spatial dimension of  an
    environmental problem is the extent
    of the geographical area that is
    affected by it. Some, like elevated
    levels of radon, may be limited to the
    basements of some homes, while
    stratospheric  ozone  depletion can
    affect the entire globe. And  some
    global problems, like the loss of
    genetic diversity, can be caused by


    human activities in relatively limited
    geographical areas.
      Ecosystems are generally resilient
    to short-term insults. For example, oil
    spills and water pollution usually
    cause only temporary ecological
    changes; nature has a substantial
    capacity for healing  itself. However,
    some changes are  either permanent or
      In fact, some long-term and
    widespread environmental problems
    should be considered relatively
    high-risk even if the data on which
    the risk assessment is based are
    somewhat incomplete and uncertain.
    Some risks are potentially  so serious,
    and the time for recovery so long,
    that risk reduction actions should  be
    viewed as a kind of  insurance

                                         Sieve Money photo.
                Risks to the Natural  Ecology and to  Human Welfare
                The following are ecological
                risks the Science Advisory
                Board felt were of considerable
                importance and  should receive
                attention in any discussions
                about current and future
                environmental risks and
                methods to control such risks.
                The order of  problems listed
                within each of the three
                different risk groups is not
                meant to imply a ranking.
Relatively High-Risk Problems

• Habitat Alteration and
Humans are altering and
destroying natural habitats in
many places worldwide, e.g., by
the  draining and degradation of
wetlands, soil erosion, and the
deforestation of tropical and
temperate rain forests.
• Species Extinction and
Overall Loss of Biological
Many human activities are
causing species extinction and
depletion and the overall loss of
biological diversity, including
the  genetic diversity of
surviving species.
•  Stratospheric Ozone
Because releases of
chlorofluorocarbons and other
ozone-depleting gases are
thinning the Earth's
stratospheric ozone layer, more
ultraviolet radiation is reaching
the Earth's surface, thus
stressing many  kinds of
• Global Climate  Change
Emissions of carbon dioxide,
methane, and other greenhouse
gases are altering  the chemistry
of the atmosphere, threatening
to change the global climate.
                                                                                                       EPA JOURNAL

Relatively Medium-Risk
•  Herbicides/Pesticides
•  Toxics, Nutrients,
Biochemical Oxygen Demand,
and Turbidity in Surface Waters
•  Acid Deposition
•  Airborne Toxics

Relatively Low-Risk Problems
•  Oil Spills
•  Ground-Water Pollution
•  RadionucJides
•  Acid Runoff to Surface
•  Thermal Pollution
                                          Global wanning and
                                          stratospheric ozone depletion
                                          are big-picture problems on
                                          which scientists and the public
                                          don't see eye to eye. The
                                          Science Advisory Board sees these
                                          as high-risk problems. In public
                                          opinion polls,  they have received
                                          medium- to low-risk rankings.
The Links Between Risk and Choice
The sources of risk often are to be
found in the day-to-day choices made
by individuals, communities, and
businesses. And many kinds of
environmental risk will not be
reduced substantially, especially over
the long term, if past patterns of
individual, community, and business
choices do not change in light of the
relative risks posed by those choices.
  Individuals either increase or
lessen environmental risk depending
on which consumer products they
buy, how they design their homes,
and whether they walk or drive to
work. Society affects environmental
risk at the local level through
building  codes and zoning laws and
at the national level through tax,
energy, and agricultural policies.
  Choice is influenced  by a number
of factors, including education and
ethics.  Some people may choose to
purchase certain consumer products
because of a genuine concern about
the environmental effects of their
personal  buying patterns. Similarly,
some businesses may redesign
production processes to eliminate
pollution because of a desire to be
perceived as corporate  "good
  Economic incentives are also
important tools for inducing
particular kinds of choices. When the
price of energy rises, consumers are
likely to buy more fuel-efficient
vehicles and weatherize their homes,
while plant  managers have an added
incentive to purchase more
energy-efficient equipment. Full
pricing of municipal services can
give people an incentive to recycle
their household wastes and conserve
  Laws and regulations  are effective
at shaping individual and social
choices. Local zoning laws can
change the pattern of economic
development in a community and
limit where homes can be built.
Local, state, and federal procurement
regulations can have a substantial
effect on the development of markets
for recycled products.
  Projected future growth  in
population and economic  activity
could add enormously to the
environmental risks faced  in this
country and around the  world. But
growth and reductions in
environmental risk are not
necessarily incompatible, if past
patterns of individual, community,
and business choice can change.

Public Perceptions Of Risk
Public opinion polls  taken over the
past  several years confirm  that people
are more worried about
environmental problems now  than
they were 20 years ago when the first
wave of environmental concern led to
major changes in national  policy. But
the remaining  and emerging
environmental risks considered most
serious by the  general public today
are different from those considered
most serious by the technical
professionals charged with reducing
environmental risk.
  This dichotomy presents an
enormous challenge to a pluralistic,

   democratic country. Since public
   concerns tend to drive national
   legislation, federal environmental
   laws are reflective of public
   perceptions. Consequently, EPA's
   budget and staff resources tend to  be
   directed at those environmental
   problems perceived to be most
   serious by the general public.
     One way to bridge the dichotomy
    would be to improve the public's
    understanding of the scientific and
    technical aspects of environmental
    risk while improving scientists'
    understanding of the basis of public
    concern. Since environmental policy
    necessarily embodies subjective
    values, scientific understanding
    should not be the sole determinant of
    environmental policy.
    Relatively High Risks To Human Health
   The following are human health
   risks that the Science Advisory
   Board felt were of considerable
   importance and should receive
   attention in any discussions
   about current and future
   environmental risks and
   methods to control  such risks.
   Available data support high-risk
   rankings for four areas. Other
   areas also involve potentially
   significant exposure of large
   populations to toxic chemicals;
   e.g., pesticide residues on food
   and toxic chemicals in
   consumer products. However,
   the data bases to  support those
   concerns are less robust.
   • Ambient Air Pollutants
   Stationary and mobile sources
   emit a range of different air
   pollutants to which large
   populations are exposed. Some
   have toxic and/or carcinogenic
   effects following  direct
   inhalation exposure (e.g., carbon
   monoxide and benzene). Other
   pollutants, such as  lead and
   arsenic, reach  humans by a
   variety of pathways including
   direct inhalation, inhalation of
   re-suspended dust,  and
   ingestion of dust  deposited on
   food products. Still others are
   important precursors  that can
   lead to compounds  such as
   ozone, acid aerosols, and
   carcinogenic hydrocarbons that
   form in the atmosphere  over
   large areas of North America.

   • Worker Exposure to
   Chemicals in Industry and
Industrial and agricultural
workers are exposed to many
toxic substances in the
workplace. Such exposures can
cause cancer and a wide range
of non-cancer health effects.
Due to the large population of
workers directly exposed to a
range of highly toxic chemicals,
this problem poses relatively
high human health risks.
•  Pollution Indoors
Building occupants may be
exposed to radon and its decay
products as well as to many
airborne combustion products,
including nitrogen dioxide and
environmental tobacco  smoke.
Indoor exposures to toxic agents
in consumer products (e.g.,
solvents, pesticides,
formaldehyde) also can cause
cancer and a range of
non-cancer health effects. Due
to the large population  directly
exposed to a number of agents,
some of which are highly toxic,
this problem poses relatively
high human health risks.
•  Pollutants in Drinking Water
Drinking water, as delivered at
the tap, may contain agents
such as lead, chloroform, and
disease-causing microorganisms.
Exposures to such pollutants in
drinking water can cause cancer
and a range of non-cancer
health effects. This problem
poses relatively high human
health risks because large
populations are exposed
directly to various agents, some
of which are highly toxic.
Recommendations for Reducing
Environmental Risk

Here are the 10 major
recommendations of the SAB's
report, Reducing Risk.

• EPA should target  its
environmental protection efforts on
the basis of opportunities for the
greatest risk reduction.

• EPA should attach as  much
importance to reducing ecological
risk as it does to reducing human
health risk.

• EPA should improve the data and
analytical methodologies that support
the assessment, comparison, and
reduction of different environmental

« EPA should reflect risk-based
priorities in its strategic planning

• EPA should reflect risk-based
priorities in its budget process.

• EPA—and the nation  as a
whole—should make greater use of
all  the tools available to reduce risk.

• EPA should emphasize pollution
prevention as the preferred option for
reducing risk.

• EPA should increase its efforts to
integrate environmental
considerations into broader aspects of
public policy in  as fundamental a
manner as are economic concerns.

• EPA should work to improve
public understanding of
environmental risks and train a
professional workforce to help reduce

• EPA should develop improved
analytical methods to value natural
resources and to account for
long-term environmental effects in its
economic analyses, o
                                                                   EPA JOURNAL

Why  We  Didn't  Use  "Risk"  Before
by Al Aim
     William C. Reilly's strong
     advocacy of the Science
Advisory Board's (SAB) recent report
on Reducing Risk has, as the EPA
Administrator intended, opened up a
debate on whether risk-based  priority
setting is feasible, desirable, and
morally proper. The conclusions of
the report—in short, that risk-based
priority setting is indeed
necessary—are anchored in 20 years'
experience with both risk-based
decision making and priority-setting
at SAB. These two distinct concerns
were linked initially with EPA's 1987
internal report Unfinished Business
and embellished in the SAB report.
Their linkage could have profound
implications for the future of
environmental programs.
  The term "risk" was rarely used
during EPA's formative years. In the
early 1970s, the  public, Congress, and
EPA were primarily focused on
curbing the damages from gross air
and water pollution. The early
symbols of environmental
degradation included a burning
Cuyahoga River, a dying Lake Erie,
and a smog-choked Los Angeles.
  With these problems so firmly
etched in public consciousness, the
Agency declared a holy war against
pollution of all forms. These
absolutist concepts were applied
mainly to air and water pollution but
were also carried over into control of
hazardous chemicals. Although EPA's
pesticide legislation balances  risk
versus value (economic and social
benefits] of pesticides, much of the
early legal reasoning behind the
Agency's actions on cancellations
and suspensions was based on the
premise that any threat of cancer was

(Aim, a former Deputy Administrator
of EPA, is now Director and Senior
Vice President of the Science
Applications International
Corporation in McLean,  Virginia.]
 Setting priorities was not a
 problem during EPA's early
  However, as the Agency began to
deal with an onslaught of chemical
contamination problems—Kepone  in
the James River, mercury in the Great
Lakes, and PCBs almost
everywhere—it became clear that a
new decision-making process was
necessary. It was simply going  to be
impossible to ban all potentially
harmful chemicals.
  The threat of cancer provoked the
first steps toward the formal process
      research can
    identify specific
   risks, such as the
       potential of
    compounds, but
   necessarily plays
   a significant role
    in comparative
    risk assessment,
   which entails the
        ranking of
     diverse health
    and ecological
decisions relating to cancer and for
comparing one cancer risk against
  The working group recommended
to the Administrator the creation of a
Carcinogen Advisory Group (CAG)—a
small staff that would analyze the
cancer risk of individual decisions.
The CAG was the forerunner of the
Office of Health and Environmental
Assessment (OHEA), created in 1980
within the Office of Research and
Development, Betty Anderson moved
from heading up the CAG to the
leadership of the newly created
OHEA. In addition, a risk assessment
staff had been created in the Office of
Pesticides and Toxic Substances to
help support the Toxic Substances
                   EPA photo.
of risk assessment. After being
briefed on the range of carcinogens in
the environment—including to his
dismay, liquor—the Administrator
Russell E. Train directed me, as
Assistant Administrator of Planning
and Management, to develop a
"cancer policy." Working with
excellent EPA staff—Betty Anderson,
Walt Barber, and Tony Cortese—we
concluded a "policy" was both
unworkable and potentially
politically divisive. On the other
hand, we concluded that there was
no analytical framework for making
Control Act, which was enacted in
  During the last half of the 1970s,
EPA had developed the capability to
evaluate the risk of harmful
chemicals—primarily carcinogens—in
quantitative terms. By evaluating
both the potency (toxicity) and
exposure, EPA could estimate the
quantitative risk from emissions or
use of a chemical. For example, EPA
could estimate that Chemical X poses
a risk to society of 10 additional
cancer deaths per thousand people.
This practice, which is currently

                                        By the end of the 1970s,
                                        EPA's statutory authorities
                                        had ballooned.
   commonplace, was relatively new in
   the mid-1970s. Many EPA
   professionals no longer used
   bi-modal terms such as safe or
   unsafe, but rather began to think and
   talk in probabilistic terms.
     The term risk assessment did not
   gain widespread popular currency
   until  the second term of William D.
   Ruckelshaus as Administrator,
   Ruckelshaus took over the helm of
   EPA at a time of turbulence. As never
   before in its history, Congress was
   pushing EPA to make a major
   onslaught on hazardous chemicals.
   The public was demanding absolute
   safety from toxic contamination, and
   no  one was arguing the impossibility
   of such a goal.
     Ruckelshaus viewed public
   education as  one of the chief
   responsibilities of  the EPA
   Administrator. Educated  himself by
   participation on a  National Academy
   of Sciences panel on risk assessment
   and risk management, Ruckelshaus
   set out to educate  the public  on risk.
   In a landmark speech to the National
   Academy of Sciences, Ruckelshaus
   argued that zero risk was impossible:
   that society had  to accept some risks
in return for economic and social
benefits that were expected. In that
speech, he also articulated a
decision-making process that
separated risk assessment from risk
  Almost like a judge, Ruckelshaus
used individual decisions to illustrate
the need for statutory flexibility in
dealing with risk. For example, in
presenting the draft National
Ambient Air Quality Standard for
PM10 (particulates of respirable size),
he argued that the health test  in the
Clean Air Act was unreasonable. The
public forum he created to deal with
arsenic emissions at the ASARCO
Tacoma Smelter illustrated trade-offs
between environmental risk and jobs
in a local economy.
  Ruckelshaus neither invented the
techniques of risk assessment ror
was he successful in gaining statutory
flexibility from Congress. He was
successful, however, in embedding
risk assessment more deeply in the
Agency's decision-making  process
and in changing the perception of
senior EPA staff.
  Ruckelshaus did not deal explicitly
with comparing the relative risk
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                                                                    EPA photo.
between environmental problems,
although the genesis of this idea took
form during his tenure. Nor did he
really explicitly focus on ecological
risk. These issues were to be faced
later during the Thomas and Reilly
  Setting priorities was not a problem
during EPA's early years. During the
early 1970s, the public, Congress,
EPA, and the experts pretty much
agreed about the severity of
environmental problems the country
was facing and what needed to be
done to correct them. Public outrage
was focused on ecological threats
from water pollution and health and
aesthetic threats from air pollution.
With agreement on the problems
among EPA, Congress, the public,
and most experts, EPA was able to
focus its efforts and resources on
massive clean-up  programs.
  Over time, however, EPA's
authorities began to strain resources,
and the Agency, not surprisingly, lost
focus. In 1974, the Safe Drinking
Water Act (SDWA) was passed—the
first major new authority since the
creation of the Agency. On the heels
of the SDWA, the Toxic Substances
Control Act  (TSCA) and the Resource
Conservation and  Recovery Act
(RCRA) were enacted in 1976. In
1980, the Comprehensive
Environmental Recovery and
Compensation Liability Act
(CERCLA)—popularly known as
Superfund—was enacted.
  By the end of the 1970s,
EPA's statutory authorities had
ballooned. The SDWA and TSCA
were being implemented as  full-scale
programs, but RCRA implementation
was at  an early stage, and CERCLA
implementation was just beginning.
During that time, budgets had
increased substantially to meet the
                                                                             Asbestos and other potential indoor air
                                                                             pollutants are relatively new
                                                                             environmental concerns. The agenda of
                                                                             unfinished business has grown, not
                                                                             diminished, since EPA's 1970 creation.
                                                                                                     EPA JOURNAL

     What is Comparative Risk Analysis?
      Setting environmental priorities
      will never be easy. Many
      problems beg for attention.
      While a variety of factors must
      be considered, the
      priority-setting process must
      take into account some estimate
      of the relative seriousness of the
        Comparative risk projects are
      simply a formal way of
      gathering together available
      information and professional
      judgments to  produce  estimates
      of relative seriousness. The
      1987 Unfinished Business
      project,  the 1990 Reducing Risk
      project,  and the various other
      comparative risk projects
      mentioned in this issue of EPA
      Journal  have shared several
      • Teams of 20 to 75 experts
      from different fields list the
      problems to be analyzed.  The
      list typically includes  criteria
      air pollutants, radon, active
      hazardous waste sites,
      pesticides, and so forth. There
      are different ways of dividing
      up the problems, and teams
      have listed from as few as 18 to
      as many as 31.
      • Participants define different
      types of risks by which the
      problems will be compared.
      Typically, they include cancer,
      non-cancer health effects,
      ecological effects, and welfare
      effects, such as materials
      damage  and economic losses.
      Because there is no commonly
      accepted way of "adding" these
      risk types, all teams have kept
      the comparisons separate. The
      participants also agree on
      ground rules, such as looking
needs of new programs, as well as to
beef up existing ones.
  The Gorsuch regime attempted to
reverse the two driving forces at the
end of the Costle period—expanding
the environmental agenda and
expanding resources devoted to EPA
programs. The new Administrator,
Ann Gorsuch, believed EPA could
"do more with less" by better
 only at risks that remain after
 current controls are applied.
 • Participants assemble data on
 each problem and compare the
 relative seriousness by risk type.
 Because there are gaps in data,
 and because data are often not
 strictly comparable, there is no
 way of making the comparisons
 precise. Thus, each team has
 had to use considerable
 judgment to produce rankings.
 It is rarely possible to
 accompany rankings with good
 quantitative estimates of total
 impacts. In fact, each team has
 stressed that its comparative
 rankings are only rough
 judgments.  Nevertheless, they
 have all had confidence that
 their higher ranked problems
 are more serious than their
 lower ranked problems.

   The results of comparative
 risk projects are being used as
 one type of aid to inform the
 debates on environmental
 priorities. Other factors that
 must be considered include
 statutory mandates, public
 concern (which may vary
 substantially from the
 comparative risk project
 rankings), the status of existing
 programs, the economic or
 technical controllability of the
 risks, the benefits to society of
 the  activities that cause the
 environmental problems, and
 the qualitative aspects of the
 risks that people find important,
 such as equity. Comparative risk
 analyses can also yield insights
 on individual problems
 concerning sources, pathways
 and exposures that are useful  in
 identifying opportunities to
 reduce risks.
management and a clearer sense of
the federal role. In a sense, priorities
were established by substantial cuts
in most EPA programs to make room
for the new hazardous waste
  The Ruckelshaus team faced
serious budget problems when it took
over management of the Agency in
1983. The traditional EPA programs
had been reduced substantially from
the Costle budget. Congress was
about to make dramatic changes to
RCRA, and CERCLA reauthorization
was on the horizon.
  The 1984 amendments to RCRA
brought the issue of priorities to a
head. The 1984 RCRA
reauthorization, with its massive shift
of emphasis,  was going to require
substantial increases in personnel
and dollar resources. As Deputy
Administrator, I had to make room
for large RCRA increases and at the
same time provide some relief to
traditional EPA programs. But  how?
No machinery existed to make such
choices. Reacting to this
unsatisfactory state of affairs, I
directed the Agency's Office of
Policy,  Planning, and Evaluation
(OPPE) to study how risk-based
priorities could be developed.  The
immediate budgetary decisions were
made with minimal analytical  back-
  The subsequent OPPE staff study
pointed out a wide disparity between
the risk associated with many EPA
programs and the level of resources
devoted to them.  Because only OPPE
participated in the study, however,
Office Directors and other line
managers were not committed  to the
study's  results and were at least
mildly apprehensive about them. If
risk-based priorities were to have any
chance  of becoming a serious part of
EPA decision making, wider
participation  in the priority-setting
process was imperative.
  OPPE staff, to their great credit, did
broaden participation to include
many of the Agency's most respected
senior managers. The "best and
brightest" of EPA's senior staff
participated in ranking risks  in four
different categories: cancer health
risk, non-cancer health risk,
ecological risk, and welfare risk. In
February 1987, the report of this
internal task force, entitled
Unfinished Business, was released.
While Unfinished Business was a

   critical success among senior EPA
   staff and thoughtful outsiders, it had
   limited impact on Agency priorities
   and on internal operations.
     The report did, however, catch the
   eye of William Reilly, then President
   of World Wildlife Fund and The
   Conservation Foundation.
   When Reilly became EPA
   Administrator two years later, he
   decided to appoint an outside group
   to go through a similar exercise in
   developing risk-based priorities. After
   reviewing several options for outside
   participation, he finally chose the
   EPA Science Advisory Board (SAB)
   as the instrument for conducting the
     The final SAB report, Reducing
   Risk, strongly argued that risk-based
   priorities were critical to protecting
   the public and the ecosystem. The
   report also suggested that ecological
   risk should be  given equal billing to
   health concerns; that a greater range
   of tools should be employed toward
   reducing risk, such as market
   incentives and information; and that
   other national policies, such as
   energy and agricultural policy,
   needed to reflect environmental
   concerns. While calling for upgrading
   analytical tools, the report also
   recognized that informed judgment
   would play a role in the development
   of risk-based priorities.
     The timing of the SAB's report,
   released in September 1990, was
   perfect. Almost 20 years after EPA's
   creation,  the need for coming to grips
   with priorities had never been
   greater. Old problems, such as
   nonpoint-source water pollution or
   smog, had defied solution. The
   implementation of RCRA and
   CERCLA  was still in the early stages.
   New problems reached political
   prominence, such as radon, asbestos,
                       and other forms of indoor air
                       pollution; ozone depletion; species
                       diversity; and global warming. The
                       backlog of unfinished business had
                       grown, not diminished, over time.
                         Second, it was clear that resource
                       constraints were going to be a reality
                       in the foreseeable  future. EPA's
                       budget over recent years has been
                       relatively flat. It increased only about
                       Almost 20 years after EPA's
                       creation, the need for
                       coming to grips with
                       priorities had never been
                       10 percent between 1990 and 1991,
                       and the Administration's proposal for
                       fiscal year 1992 was an even smaller
                       percentage increase. Beside the
                       general limitations on federal
                       spending, EPA is also faced with
                       extreme competition within its
                       appropriations subcommittee. The
                       Independent Offices Appropriation
                       subcommittee must  weigh EPA
                       resource needs against those of the
                       National Aeronautics and Space
                       Administration (NASA), which has a
                       politically sophisticated constituency;
                       the Department of Veterans Affairs,
                       recently upgraded to Cabinet status;
                       and the National Science Foundation,
                       which funds basic R&D, an
                       Administration priority. The paucity
                       of funds for discretionary federal
                       programs, coupled with this
                       institutional rigidity, almost
                       guarantees the EPA's budget will lag
                       behind legislative expectations by a
                       large amount.
                         The SAB report solidified the
                       coalescence of risk and
                       priority-setting into the concept of
                                  relative risk. As a concept, risk could
                                  not only be used to guide individual
                                  decisions, it could also be used to
                                  rank risks against each other. In some
                                  cases, such as cancer risk, the risks
                                  could be compared quantititatively.
                                  In most cases, however, professional
                                  judgment must be used to rank risk,
                                  backed up by the best analytical data
                                  possible. For example, judgments are
                                  necessary to compare suffering by
                                  asthmatics from air pollution to
                                  premature deaths from human
                                  exposure to a carcinogen. And
                                  judgments are necessary  to compare
                                  the potential risks from global
                                  warming to oil spills. Answers to
                                  these questions require judgment,
                                  experience, and adherence to criteria;
                                  no analytical "silver bullet" can make
                                  these decisions for us.
                                    Establishing relative risk rankings
                                  does not necessarily translate to
                                  budgetary and programmatic
                                  priorities. Managers must ultimately
                                  rank relative risk reduction potential.
                                  That is, a moderately high risk may
                                  be amenable to a great deal of risk
                                  reduction at low cost, while
                                  addressing a higher risk might be less
                                  feasible and much more expensive.
                                    The SAB report does not reveal any
                                  blinding new insights or divine
                                  revelations. In fact, it is no more than
                                  a synthesis of policy and analytical
                                  ideas and processes  that  have
                                  developed over the last 20
                                  years—particularly those relating to
                                  risk assessment and  priority setting
                                  that were embodied in Unfinished
                                  Business. It is nevertheless a very
                                  influential document. Never before
                                  has such a distinguished group of
                                  scientists reached such a strong
                                  consensus of the need for new
                                  directions, and equally important,
                                  never has an Administrator embraced
                                  changes with such gusto, a
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                                                                                                   EPA JOURNAL

Two Forums—The  Policy and the Science
                                  Mike BoyJan photo.
The Debate
 In a recent report, EPA's Science
 Advisory Board argued that we
should make certain our spending on
the environment achieves the
maximum reduction in risk. The
board recommended that we use
scientific analysis of the relative risk
of environmental threats as the basic
yardstick for assigning priorities to
  Few would dispute the desirability
of getting the biggest bang for our
buck, but there is a variety of opinion
on the rest of the argument. To
provide our readers with a
comprehensive roundup of views on
this issue, EPA JournaJ organized two
  In the first, leaders in the
environmental field were asked:
Should Congress, and by implication
EPA, revise the current ordering of
the nation's environmental program
priorities to better match scientific
assessment of the relative risk of the
various threats  to the environment?
  In the second forum, a number of
scientists were asked:

Is the science of estimating risk
sufficently advanced so that we can
rely on it to help order our priorities
and allocate resources for
environmental programs?

  The two forums follow:

                    FORUM  ONE—THE  POLICY
                    Should  We  Set Priorities
                    Based on  Risk  Analysis?
Daniel Patrick
(Moynihan (D-New
York) serves on the
Senate Environment
and Public Works
 If it can be said that we have a
 "national environmental
policy," it can only be the sum
total of the environmental laws
Congress has enacted over the
past two decades. In studying the
nature of this "national policy,"
EPA's own Science Advisory
Board has come upon an
interesting pattern. The priorities
reflected in our laws have much
more in common with the
public's perception of
environmental risks than they do
with a rigorous scientific
assessment of these risks. This is
not surprising. The question we
must confront is whether it is
desirable—and what to do if we
decide it is not.
  Reducing risk is not about any
particular environmental
problem, or any particular
environmental bill. It is about a
set of ideas—matters of
environmental philosophy—the
fundamental principles we
should use in setting priorities.
Which risks are greater and
which are lesser? If we can come
to a consensus on what these
principles are to be, future
environmental debates will be
more rational (and more
peaceable) than those to date.
  Of course, it should  not be
assumed that reduction of the
overall risk is the only factor to
consider in making
environmental policy.  Matters of
social equity, for example, must
be considered. Coal miners in
Appalachia will be paying a
much  higher price for  reductions
in acid rain than an average
citizen, and it is also argued that
the poor are exposed to pollution
much more than the affluent.
Nonetheless, as a principle of
government, the prioritization of
environmental problems is a
sound starting point. It is, as Mr.
Reilly has said, "common sense."
  I call special attention to two of
the report's recommendations:
• EPA should improve the data
and analytical methodologies that
support the assessment,
comparison, and reduction of
different environmental risks.
• EPA should develop improved
methods to value natural
resources and to account for
long-term environmental effects
in its economic analysis.

Taken together, these
recommendations make a
compelling case for a topic that I
have been interested in for some
time, which is the
commencement of rigorous
benefit/cost analysis for
environmental laws. As a  start,
Section 812 of the Clean Air Act
Amendments of 1990 will require
EPA to perform benefit/cost
analysis for its clean air
  Of course, we know  that
answers do not come quickly in
these matters. Almost three
decades ago, I became  an
Assistant Secretary of Labor in
the administration of John F.
Kennedy, with a nominal
responsibility for the work of the
Bureau of Labor Statistics,
founded in 1884. If there is one
thing those brilliant
mathematicians and public
servants taught me, it is that
fashioning economic indicators
takes time. It had taken them a
half century to learn to measure
unemployment. But they were
patient and meticulous, and in
the end they  succeeded. With
this success they changed the
way we think about an industrial
(or post-industrial) society. I have
no doubt that it will take quite a
long time to develop reliable
methodology to assess the costs,
and even more difficult, the
benefits of environmental
regulation. But this is no reason
not to begin.
                                                                                                 EPA JOURNAL

                                Jonathan Lash
                                (Lash was co-chair of
                                the EPA Science
                                Advisory Board
                                committee which
                                prepared the
                                Reducing Risk
                         Chicken Little, it turns out, has
                         occasionally been right. From
                     hairspray to Hanford, the dire
                     warnings of lonely voices have
                     proven to be accurate, and
                     conventional wisdom—often
                     dispensed with condescension or
                     even hostility—has turned out to
                     be wrong.  But Chicken Little has
                     sometimes been wrong too, or at
                     least overwrought. Some risks are
                     not worse, but less serious than
                     we feared. The public is skeptical
                     and confused. One recent poll
revealed that 80 percent agreed
with the statement, "There are so
many contradictory things said
about the environment that it is
sometimes confusing to know
what to do."
  Both Unfinished Business and
Reducing Risk express the
judgment of scientists and
environmental officials that some
risks,  such as global climate
change and indoor air pollution
that have received little attention
in national  policy, are far more
significant than others, such as
inactive hazardous waste sites,
which have received a great deal
of attention. To date, our
problem-by-problem political
response to environmental policy
has caused  us to look at the
world and time in pieces,
breaking apart the complexity of
environmental degradation in
order  to simplify the attempt to
regulate its  causes. For regulatory
purposes, we separate air
pollution from water pollution
from hazardous wastes. We issue
permits plant by plant and
pollutant by pollutant but seem
to lack a coherent understanding
of the interrelationship of
environmental effects and their
  Public policy in the United
States reflects public perceptions.
Public perceptions about the
environment are based on a
haphazard combination of good
and bad information, well
learned fear, outrage, and
skepticism about official
assurances minimizing risks.
Over the past 20 years, we have
responded to new discoveries
about the nature and extent of
environmental risks with a
patchwork of laws that better
reflect our political history than
ecologists' understanding of the
Earth. We have mitigated or
postponed some environmental
problems, but there is much that
we have not addressed, and some
of our solutions have created new
  Risk assessment by itself offers
no escape from the quandary.
Risk assessors look at the
narrowest of questions: What is
the risk of cancer to  a
hypothetical population exposed
to an assumed level  of a specific
substance? In most cases, the
answer to even that narrow
hypothetical question is only an
estimate. It is far more difficult to
calculate actual risks to real
people or to ecosystems.
  Even if we knew enough to
calculate risks with certainty,
there is another problem with
risk as a tool for making policy.
The concept of risk is
meaningless until we decide
what risk of what harm to what
values we wish to consider. Do
we consider only the risk of
death, or also the risk of illness?
Are all lives the same, or are
future lives less important than
current lives? How do we
compare risks  to human beings
and risks to ecosystems? Even  if
we could precisely calculate the
risks created by human activities
that affect the environment, that
would provide only a piece of
information to use in making
environmental policy. We  would
still have to decide what values
are important enough to us to
protect from risk, and how much
risk is too much.
  The comparative risk
assessment process described in
Reducing Risk offers a framework
for the use of risk information  in
shaping environmental policy. It
requires an explicit and
thoughtful decision about what
sources of risk and what values
at risk to consider, and about
how to recognize uncertainty.
Environmental policy has both
scientific and moral content.
Comparative risk assessment
provides a structure for a debate
which considers both.

                     Representative J. Roy

                              (Rowland ID-Georgia)
                              is a member of the
                              House Committee on
                              Energy and
 I~hose who advocate the use of
 I "risk assessment" to evaluate
environmental dangers appear to
be gaining ground in Congress.
  It's about time. For more than
20 years the federal  government's
efforts to achieve a cleaner
environment have often been
influenced more by  fears than by
scientific findings. The resulting
patchwork of laws has made it all
but impossible to address prob-
lems rationally and  consistently.
  Four years ago, when the
House Science, Space, and
Technology Committee called on
EPA to use "scientifically sound
methodologies" to assess the risk
of ground-water contaminants,
they conceded that risk
assessment was not  a perfect
science. Scientists sometimes
interpreted data differently, or
they had to make decisions on
the basis of data that was
incomplete. However, the
committee pointed out, risk
assessment was a highly useful
tool for policy makers.
  In my view, risk assessment is
more than a useful tool; it is
unavoidable. Even those who
argue that toxic chemicals should
be banned without regard to cost
have to rely on science to
identify the chemicals that are
  Nevertheless, there continues
to be substantial opposition to
any deliberate effort to use risk
assessment in designing
regulatory programs. We faced
this opposition in trying to
incorporate risk assessment in
the Clean Air Act.
  Opponents argued that risk
analysis could not substitute for
moral values, and that scientific
knowledge was too  uncertain to
provide a reliable foundation for
decisions. These views missed
the point.
  Risk analysis cannot replace
moral values, but the information
provided by risk analysis can
guide us in making  choices that
respond to moral values. And,
since perfect information will
never be available, these choices
must be based on the best
information we have. When we
are sick, we consult physicians
knowing they sometimes
disagree; we are aware that they
may not know all there is to
know about a disease. To behave
differently when environmental
protection is concerned would
not be responsible.
  I was pleased to have Congress
endorse the concept of risk
assessment last year by enacting
provisions in the new Clean Air
Act that require a detailed study
of both the scientific and  policy
questions surrounding the
regulation of hazardous
pollutants. I was a co-author of
these  provisions.
  Risk assessments had seemed
almost irrelevant in previous
deliberations over the act, even
though it had been part of the
overall environmental debate for
many years. The act's grounding
in absolute protection of health
had precluded modification by a
risk assessment process.
  The environmental community,
which was in the forefront of the
phenomenal progress made over
the past two decades, has been
prominent among the doubters of
risk assessment. I believe they
strike a poor bargain when they
resist  risk analysis to preserve
yesterday's victories. Without the
support of risk analysis, problems
that are  important,  but that are
also politically unrewarding to
address, may be ignored by the
  If our environmental laws were
already based on risk assessment,
the regulatory system, itself,
would advance our knowledge of
environmental problems and
their relative importance. The
new risk assessment provisions
of the Clean Air Act hopefully
will point Congress in the right
direction. By insisting on the
application of these findings to
other  environmental laws,
Congress can help move the
country toward a new era of
environmental progress by
assuring that our limited
resources are used  in the most
effective way possible.
                                                                                                       EPA JOURNAL

                      Lawrie Mott
                      (Mott is a senior
                      scientist at the
                      Natural Resources
                      Defense Council.)
                       phe notion of using science to
                       I  revise priorities for
                      environmental programs is
                      tempting but ultimately will
                      result in reduced protection of
                      public health and the
                      environment. Setting
                      environmental priorities on the
                      basis of scientific comparisons of
                      risk is unrealistic and ignores the
                      intricate complexities of
                      environmental problems. Setting
                      priorities this way also assumes
                      that we must choose which
                      hazards to address and cannot
                      seek to solve all environmental
                       The very nature of scientific
                      research is to raise as many
                      questions as it answers. Debates
                      in any scientific forum are just as
                      heated as in the courts or
                      Congress. To assume that science
                      will be able to determine,
                      empirically and without
                      disagreement, which
                      environmental problems are the
                      worst is  naive.
                       Certainly science can provide
                      valuable information, but it
                      cannot be the ultimate arbiter for
                      fundamental questions about how
                      society can best protect the
                      environment. Important issues
                      intrinsic to environmental
                      hazards do not lend themselves
                      to incorporation in scientific risk
                      assessment. For instance, certain
environmentally hazardous
activities can provide benefits to
one segment of society but
present risks to another group.
How can science indicate that the
actions of some individuals will
necessarily harm others?
Similarly, how does a scientific
risk assessment take into account
when a risk is entirely  avoidable
or preventable through a
technological innovation?
Likewise, involuntary risks are
more objectionable than
voluntary ones. Yet science is
ill-equipped to convey  that
fundamental belief. And consider
children  who may already be
inadequately protected by
scientific risk-assessment
procedures. What if, as a society,
we deem—and we
should—children our most
important resource? Analytical
risk comparison cannot reflect
that choice.
  The environmental problems
we know about today are very
complex, with limited  scientific
knowledge about these issues.
Mechanisms of toxicity are
minimally understood for
carcinogens. For others, such as
reproductive toxicants  and
neurotoxins, we know even less.
Data on exposure to toxins are
scarce. Then consider
endangered-species loss,
wetlands degradation, and global
warming. These very different
problems cannot be reduced to
one dimension for comparative
  This quest towards relative risk
priorities signals a basic failure
in our efforts to protect public
health and the environment.
Basing environmental priorities
on relative risk will quickly lapse
into environmental triage. The
top three or five or even ten
issues will receive attention,
resources, and perhaps some
progress will be made in these
areas. Other risks  not on the
short  list will languish, or worse
yet, be ignored. Triage serves a
useful function in  the emergency
crisis  on the battlefield. But
environmental protection cannot
become management through
triage. If current resources are
inadequate for addressing
environmental problems, we
should seek additional means.
Pitting Superfund  against
pesticides against air pollution is
counterproductive. We should
strive to solve all,  not just some,
environmental problems. To
admit that we can do anything
less, as comparative risk
assessment necessarily does,
indicates our ultimate failure to
protect public health and the

Joseph I.
(D-Connecticut) is on
the Senate
Environment and
Public Works
 A dministrator William Reilly
*»should be commended for his
foresight and guts in
commissioning the landmark
report of the Science Advisory
Board: Reducing Risk: Setting
Priorities and Strategies /or
Environmental Protection. The
report contains enormous
challenges for EPA, Congress,
industry, scientists, and the
  One of the report's principal
recommendations is that EPA
must stop  being a "reactive"
agency in  which problems are
addressed in a piecemeal fashion
as they arise; instead, EPA
should be "proactive" and set
priorities for reducing
environmental risks that are
based on opportunities for the
most cost-effective options for
risk reduction. 1 agree with this
recommendation. It is critical for
EPA to look ahead and make the
best use of its limited resources
to obtain the broadest reductions
in risk to human health and our
natural ecosystems.
  In setting priorities to achieve
the greatest risk reduction, I
believe that EPA must rely on the
latest scientific information
available and address
environmental problems in an
integrated manner. For example,
the health and environmental
risks of a chemical should not be
evaluated  only in the context of a
specific statutory scheme.
Instead, the goal should be to
apply the  most sophisticated
tools to develop an approach
which reduces the risk of the
chemical across all media and
  EPA's Strategy /or Reducing
Lead Exposures (February 1991)
begins to focus on ways to
identify and address the most
serious existing exposures to
lead. The  health risks are not
unique to  just a single exposure
medium, but come from multiple
sources—lead-based paint, urban
soil and dust, and drinking
water. While I have concerns
about the adequacy of aspects of
EPA's strategy, I believe the
coordinated effort to address the
most significant environmental
risk to America's children could
serve as a model for addressing
other environmental risks.
  At the same time, the lead
strategy highlights major
concerns I have regarding the
implementation of an effective
risk reduction program. Any
effective program must be backed
by a budget that reflects the
importance of these priorities.
The SAB report acknowledged
the need for EPA to shift its
budget priorities toward those
problems posing the greatest
risks. Unfortunately, EPA's
budget proposed only $4 million
for the implementation of the
lead strategy in 1992. This
completely inadequate budget
proposal undermines the
credibility of EPA's  entire effort.
  As recommended by the SAB,
EPA needs to establish itself as
the leader on the nation's
decisions on environmental risk.
If Congress and the  public are to
have confidence in  decisions
based on risk, we must be
convinced that those experts
entrusted with the responsibility
to guard human health and the
environment are actually  making
the risk decisions.
  Yet we are confronted regularly
with intervention by other
agencies, such as the Office of
Management and Budget (OMB),
the Domestic Policy Council, or
the Vice President's Council on
Competitiveness, which dictate
environmental decisions to EPA.
For example, OMB, in its 1991
introduction to the "Regulatory
Program of the United States,"
lashed out at EPA's risk
assessment methods, decrying
conservatism in risk assessment
because it "distorts  the regulatory
priorities of the federal
government." At the Environment
Committee's hearing on the risk
reduction report, I congratulated
Administrator Reilly for his
defense of EPA's conservative
approach and noted that,
contrary to OMB's position, some
experts believe that EPA is not
conservative enough since its risk
assessments have focused on
cancer and have not taken into
consideration other health effects
such as neurological and
reproductive risks.
  The bottom line is that EPA
should be the nation's chief
spokesman on all environmental
issues, including issues that arise
in the context of transportation,
energy, housing, and agriculture.
The distinguished scientists
involved in the SAB report
highlighted the  importance of
this role for EPA.
  The SAB report also contains
other innovative
recommendations. Most
important,  it urges that pollution
prevention be our first line of
environmental defense. Pollution
prevention is a cost effective
approach to environmental
protection. A pollution
prevention strategy can result in
savings to American industry as
well as help industry compete in
the global market by encouraging
the efficient use of energy and
raw material and stimulating the
development of new technologies
and "safer" chemicals. In March,
I introduced legislation which
would require industries to
prepare plans setting forth goals
for pollution prevention. The
goal  of this legislation is to assist
industries in understanding the
benefits of  pollution prevention
—that it  is  a "win-win" situation
for both a clean environment and
a business bottom line.
  I look forward to working with
EPA as it strives to integrate the
SAB's recommendations into its
                                                                                                        EPA JOURNAL

Bernard  D.
(Professor Goldstein
is chair of the
National Academy of
Sciences Committee
on Risk Assessment
Methodology and
Director of the
Environmental and
Occupational Health
Sciences Institute.)
    For a risk scientist to oppose the
    use of risk assessment in
  ordering EPA's priorities is as
  unexpected as the "man bites
  dog" story favored by news
  editors. However, this risk
  scientist would like to bite the
  dog of risk assessment being  used
  as the primary driving force in
i EPA's prioritization process.
I Most certainly, I do strongly
  support the use of science to
  determine the relative risk of
  environmental hazards. And  most
I certainly, I fully agree that the
  protection of health from
  environmental threats is best
  served by applying the greatest
  resources to the biggest threats.
  However, there is a disconnect
  between what is measurable by
  the science of risk assessment
  and what are the greatest threats
  to environmental health.
   Perhaps the best  way to
  describe this limitation in the
  ability of risk assessment to fully
  define EPA's priorities is to
  consider the basic concepts of
  prevention. In public health we
  usually speak of three modes of
  prevention: primary prevention,
  the most effective, consists of
  actions which prevent the
  problem or threat from ever
  developing; secondary prevention
  deals with this threat in its early
  stages; while tertiary prevention,
  in essence, deals with the
  treatment of the adverse effect
  once it has occurred.
   Reducing risks measured
  through the risk assessment
  process is a form of secondary
  prevention. Setting priorities for
  pollution prevention is
  performed through a quantitative
  risk assessment which depends
  upon correctly interpreting the
  potential impacts of pollutants
  whose presence is quantifiable.
  While it is important to use risk
  assessment to set priorities
among the various existing
problems which require
mitigation and cleanup, it is even
more important to prevent future
problems of potentially far
greater magnitude.
  How is primary prevention
applied to environmental health?
A simplistic approach would be
to remove any possibility for any
exposure in any situation. This is
not possible, nor is it desirable to
focus equally on all agents,
regardless of their risk. The best
approach is to understand the
mechanisms by which chemical
and physical agents produce
biological effects  in humans or in
ecosystems. This understanding
permits appropriate choices to be
made in a cost effective manner
that translates itself into primary
prevention. Today, a
manufacturer searching for a new
chemical product has a number
of short-term predictive tests
which quickly guide whether to
develop the chemical for market.
For example, a positive Ames
Test for bacterial  mutagenicity
will lead to this chemical being
put back on the shelf and a
redirection of R&D effort
elsewhere. The Ames Test, and
other short-term assays, are the
outgrowth of a long series  of
basic research studies aimed at
understanding the underlying
mechanisms by which disease
processes occur. For the Ames
Test, it was first necessary to
understand the mutagenic  basis
of carcinogenicity, the role of
changes in the genetic code as a
basis for mutation, the metabolic
basis for the conversion of certain
chemicals to carcinogens, and the
means by which mutations can
be expressed in bacteria.
  A budget process that focusses
on those problems that already
exist because their risk can be
quantified may well do so  at the
expense of support of primary
prevention approaches. For
example, the provisions of TSCA
(the Toxic Substances Control
Act) that are related to the
clearance of new compounds
require a strong knowledge base
and a highly expert staff for what
is a classic primary prevention
approach. In addition, the
research budget is likely to be
further torqued in the direction
of existing problems rather than
the longer term anticipatory
approach that leads to effective
primary prevention.
  In my view, the most important
contribution of EPA has been the
prevention of what has not
happened at all. Scientific
understanding has permitted us
to develop tests which now
greatly reduce the likelihood that
new chemical or physical  agents
will result in deformed babies or
dead fish.
  While continuing to emphasize
risk assessment as a means to
prioritize the approach to
existing problems, EPA needs to
assign  a high level of priority to
the much more cost-effective
approach of anticipating and
preventing new environmental
problems. It is difficult to  know
what would have happened  but
did not. There have been
numerous attempts to use
quantitative methods to
determine the value of primary
prevention, often resulting in
complex mathematical formulas.
In my judgment, the most
accurate quantitative expression
of the relative value of primary
prevention, as expressed in
standard risk assessment
terminology, is .016 x 103/1.0.
This is equivalent to 16:1 and is
based on the well-known folk
statement that an ounce of
prevention is worth a pound of

Bob  Traxler
(Traxler (D-Michigan)
is Chairman of the
House Appropriations
Subcommittee on VA,
HUD, and
 In recent years, the scientific
 community has focused
attention on the haunting
possibility that humankind is
threatened by changes in the
global environment. As the world
pppulation continues to multiply,
and as agrarian societies continue
to industrialize and develop a
preference for the lifestyles of the
industrialized world, there is the
strong possibility that humanity's
actions may be putting  our global
habitat at risk.
  This threat to human survival
is evolving gradually, and it isn't
always apparent to citizens. The
U.S. Congress must respond to
the will of the people it
represents.  However, if the
people don't perceive the threat,
Congress may face conflicting
priorities. The differing demands
for action by U.S.  citizens and
the scientific community could
cause a legislative stalemate.
  In addition, there are financial
and budgetary concerns. For
instance, policy options that limit
the amount of carbon in the
atmosphere could easily exceed
the financial resources  and the
economic capabilities of the
nation  and  the industrial world.
  EPA's Science Advisory Board
has identified a mismatch
between  the priorities of the
scientific community and the
priorities of the public  and has
rightfully expressed alarm. This
gap in comprehension of the
risks involved  in global
environmental change is a rising
challenge that can be met only
through national leadership.
  The very existence of a gap in
the United States, the most
advanced communications
society in the world, underscores
the seriousness of the gap in
comprehension that exists in the
developing and newly
industrialized countries. We can
hardly expect that the
economically deprived peoples of
these societies will be motivated
to curtail slash-and-burn
agricultural practices or the
release of pollutants from
emerging industries.
  Given the global interlocking
nature of the  new threats to
human survival, an
unprecedented worldwide
consensus may be required to
address them effectively.
Institutionalizing relative risk
assessment as an integral part of
policy  making would contribute
importantly to worldwide
decision making.
  I believe  it  is of utmost
importance that we establish
institutions and mechanisms for
informing policy makers and the
public of the  scientific consensus
on the risks, the priorities, and
the rationale for  proposed
responses to global change. I
believe our nation not only has
the technological capability of
achieving this goal, but has the
moral responsibility to do so.
  As Chairman of a congressional
committee which has funding
responsibility for science and
environment, I have proposed,
and my colleagues have accepted
in the fiscal year 1990
appropriations bill, the initiation
of a process to develop options
for creating a mechanism to share
global change information. This
effort is being conducted by the
Consortium for International
Earth Science Information
Network (CIESIN), a private
non-profit organization of the
leading university, corporate, and
private non-profit institutions
with strong capabilities in
information and environmental
  As a nation, we have invested
billions of dollars in scientific
study of earth sciences, yet this
information in many instances
remains locked away in archives.
And additional data on the
human dimensions  of global
change are just starting to be
  These current practices
represent a waste of national
wealth that can be ill afforded.
We are depriving the world of an
opportunity to build upon what
we have already learned.
Moreover, in  the information  age,
many of the technologies related
to disseminating information  are
directly related to the ability of
the United States to compete  in
the international marketplace.
  We can  ill afford the waste  of
national wealth. We are
depriving  the world of an
opportunity to build upon what
we have learned. Moreover, many
of the technologies related to
disseminating information are
directly related to the ability of
the United States to compete  in
the international marketplace.
  Opening these archives to the
world could enhance scientific
investigation, public education,
and economic growth in the
United States. As our nation,  and
the international community,
continues  to collect more and
more data, the challenges
associated with global change
suggest that we have a vested
interest in developing methods
for disseminating information on
the state of our planet and the
forces causing change.
                                                                                                         EPA JOURNAL

Peter F.
 (Guerrero is
 Associate Director for
 Protection Issues at
 the U.S. General
 Accounting Office.)
 In order to answer the question of
 whether Congress and EPA
should reorder the nation's
environmental priorities, it is
important to understand the three
major forces shaping
contemporary environmental
  First, despite high  public
expectations for environmental
protection, the federal
government is sharply
constrained in its abilities to
address environmental problems.
The federal budget deficit is
estimated to approach $300
billion in 1991. Under the
Omnibus Budget Reconciliation
Act of 1990, the deficit will be
reduced  essentially through caps
on discretionary spending, which
includes  EPA  funding;  revenue
increases will  come with
economic growth.
  While  this means that EPA is
not likely to get much additional
funding,  the fact is that for the
last decade EPA's budget has
been essentially level. Even the
apparent gains under the
President's 1992 budget request
disappear once inflation is taken
into account.
  Second, there is clearly a
disparity between what the
public sees as environmental
risks and what scientific
assessments tell us. As illustrated
by the recent report of the
Science Advisory Board,  the
problems judged by scientists to
pose the  most serious risks were
not necessarily the ones that
Congress and EPA had targeted
for the most aggressive action.
  Finally, environmental
legislation and regulation have
grown increasingly complex: The
1990 Clean Air Act, for example,
is over 700 pages long. As a
result, EPA is subject to
hundreds of legislative deadlines,
litigation, and congressional
oversight that give the Agency
little flexibility to set priorities
and  allocate its resources
  How is EPA to reconcile
limited resources with unlimited
public expectations, narrow the
gap between  perceived and actual
risk, and meet legislative
mandates yet increase its ability
to respond flexibly  to
environmental problems? While
there may be no simple answers
here, one thing is apparent: EPA
cannot do it alone. It must
educate both the public and the
Congress on the difficulty of the
task  ahead. To do so,  it must
rebuild the public education and
information programs that were
largely dismantled in the 1980s.
And it must work closely with
Congress in helping to set
environmental priorities. While
EPA has  the ability and,
arguably, the responsibility to
assess the relative risks posed by
environmental problems and to
educate the public about them, it
nevertheless remains the
responsibility of Congress to
translate that information into
legislation. Over the next few
years, EPA and Congress will
have an important opportunity
for change as a number of major
environmental statutes become
due for reauthorization.
  To set rational environmental
priorities for the
resource-constrained 1990s, EPA
will also need to continue to do a
better job of assessing how well
its programs are improving the
quality of the environment. In the
past, instead of judging how well
it's doing by how clean the
environment is, EPA has
generally counted the numbers of
regulations it has issued or the
enforcement actions it has taken
as measures of progress.
  EPA's problems in this regard
are partly the result of funding
constraints that have prevented it
from fully monitoring
environmental conditions.
Moreover, developing good ways
to measure environmental
conditions  is difficult.  Although
EPA has tried to develop better
information on environmental
conditions, Congress may need to
let EPA know, through its
appropriations and oversight
activities, that continued progress
in this area is important.
  It will take time to develop the
consensus needed to reorder the
nation's environmental priorities.
EPA's efforts to put these
important issues before Congress
and the American public are
encouraging. By so doing, EPA
has set the  stage for the
important discussions that must
take place if we are to have a
more rational,  cost-effective
environmental protection
program in the  future.

Steve Symms
 (Symms (R-Idaho) is
 a member of the
 Environment and
 Public Works
     When EPA's Science Advisory
     Board (SAB) recently
recommended that the Agency
tackle public health and
environmental problems in the
order of "highest risk first,"
they were merely stating the
obvious. To do otherwise is to
throw away human lives
  The use of risk-based priorities
is necessitated by the fact that we
live in a world where resources
are limited. If resources (i.e.,
labor, time, money, etc.) were
unlimited, we could task the EPA
with full and immediate response
to every health and
environmental problem, no
matter how small or insignificant.
But since resources are not
boundless, we must carefully
pick where to focus Agency
efforts to achieve the maximum
environmental protection
possible within our limited
  It is like having a portfolio
containing loans  of varying
interest rates. In order to pay off
those loans as inexpensively and
quickly as possible, you pay first
on the  highest rate loans. The
benefit of this approach is  a
savings of dollars that would
otherwise be needlessly paid if
high rate loans persisted on the
books for a longer period of time.
Likewise, addressing the highest
risk environmental problem first
will also yield dividends, but  the
savings is not dollars: It is in
human lives and the health of the
environment in which we live.
  The use of risk assessment as a
policy tool yields a number of
side benefits besides this
essential prioritizing function.
Often, the assessment itself will
produce critical information on
the best risk reduction measure.
By breaking down the variables
that lead to a particular risk, one
can target the factor that is most
efficiently and effectively
addressed. For example, the
relative dose, the duration of
exposure, or the toxicity of the
agent itself may all contribute to
an unacceptably high
environmental risk. Risk
assessments should enable the
Agency to identify which of these
actors represents the best
opportunity in terms of policy
options for reducing the risk.
  Furthermore, once a risk
assessment has been  made,  it is
possible to more accurately
contrast that risk with benefits
and alternatives. The Agency's
recent suggestion to ban the use
of phosphate slag in
road-building is a good example
of why this is important. When
the risks of alternative
road-building materials and the
benefits (in increased road safety)
of phosphate slag are evaluated,
they far outweigh the risk posed
by use  of slag itself. By
comparing these risks, the
Agency can choose the policy
course  that truly saves lives.
Ignoring such comparisons may
cause more deaths than the
policy is intended to save.
  The SAB report goes beyond
merely recommending that EPA's
priorities be based on their
"potential for risk reduction."
The report also urges that the
Agency's budget should "more
directly reflect risk-based
priorities." To a limited extent,
that may be  accomplished within
Agency budgeting procedures. To
truly achieve the necessary
degree of budget re-allocation,
however, action on the part of
Congress is required. In fact,
Congress should be basing ALL
of its  efforts on sound scientific
risk. As the  SAB report states,
"To the extent that EPA has
discretion to emphasize one
environmental protection
program over another, it should
emphasize the program that
reduces the most environmental
risk at the lowest overall cost to
society. The Congress should aJso
be encouraged to observe this
principle in  writing and revising
legislation "  (italics added).
  Again, the SAB is only stating
the obvious: that Congress ought
to be advancing policies that save
the most lives possible, rather
than aiming wildly at whatever
environmental issue happens to
be politically popular at the time,
at the cost of needless loss of life
and unnecessary degradation of
the environment.
                                                                                                         EPA JOURNAL

                               Nicholas L.
                               (Reding is Executive
                               Vice President of
                               Monsanto Company,
                               with responsibility
                               for environmental,
                               safety, health, and
     When asked if we could set our
     priorities for environmental
programs based on scientific
assessment of relative risks, the
answer in an ideal world would
be a resounding "yes."
  In an ideal world,  EPA would
apply the talents and intelligence
of its people to pursue the most
effective means of environmental
control at the least cost. The
Agency would have  greater
flexibility in such a world to  set
environmental priorities based on
scientific risk assessment. And
Congress would be able to come
to some sensible policy
conclusions based on real threats
to the environment and how they
should be addressed.
  In the real world, however, the
only answer can be "yes,
  Yes,  health and environmental
threats should be assessed based
on sound scientific facts, not  on
public  perceptions. But do we
really have the ability to
scientifically assess relative risk?
And, assuming the capability is
there, where does that  leave the
public  in this process?
  Over and  over again, we've
seen that the public  does not
assess environmental risk on a
scientific basis. Risk is assessed
on an emotional basis,  on how
well the threat is understood, and
on whether  there  is a choice in
terms of exposure. When
environmental concerns hit close
to home, the public responds out
of fear. We saw this with Alar,
and the same response pattern is
reflected in  the evolution of the
Superfund program.
  The public fears toxic air
pollution and strongly  feels that
it must be cleaned up,  whether or
not there is  a real health risk.
That is one of the reasons
Monsanto voluntarily pledged to
reduce toxic air emissions,
worldwide, by 90 percent by the
end of  1992. The program is in
place even though the best
scientific and medical data
indicate that Monsanto's
emissions do not pose a health
risk in our plants or
  If we rely solely on scientific
assessment of relative risk to set
environmental priorities, the
public is left out of the equation.
We must be mindful of the
public's interest. Obviously, at
the same time, we must be
mindful of what the real risks are
and try to mesh these divergent
views when establishing
  We need to better inform the
public, allowing people to be
part  of the debate. Scientific
assessment of relative risk can be
viewed as a tool to help form
public opinion based on real
threats, not perceived threats.
  All those involved—the
regulatory agencies, Congress, the
Administration, the regulated
industries, and, most of all, the
public—must work toward taking
care  of the biggest risks first.
  As America began to
industrialize in the 19th century,
many assumed that natural
resources—like air and
water—were limitless and free.
Society made many decisions
based on that assumption,
decisions which have resulted in
many of the environmental
problems we have today.
  Similarly, many assume today
that America has unlimited
financial resources which can be
applied to any and all
environmental problems,
regardless of real risks or threats.
That assumption could lead  to a
misuse of resources and a
worsening of real problems. If
EPA  could align its priorities to
account for the relative risk of
environmental threats as judged
by "good science," we could
begin to better protect our

Lee M. Thomas
Administrator of EPA
from 1985 to 1989, is
Chief Executive
Officer of Law
Environmental, an
consulting firm.)
   Today's engineers, scientists,
   and environmental profes-
sionals have access to extensive
databanks and other information
resources. These represent a
whole new body of knowledge
describing the character of
pollution, its effects on the
environment, and the
relationship between
environmental quality and
human health. This information
offers some significant new
insight into pollution, also into
the subtle range of potential
environmental risk associated
with it.
  Although the data are neither
whole nor perfect, they
nonetheless provide the ability,
for the first time,  to scientifically
assess and compare the relative
risks of several major air, water,
and land-based pollution
problems. Comparative risk
assessments performed to date
clearly show discrepancies
between real environmental
problems and how people
perceive environmental risks.
Despite these findings, the
institutional response towards
focusir"-  jn the most severe
environmental problems so far
has been limited.
  Although complete information
is not available to assess
comparative risk,  should
Congress apply relative risk and
call for a reordering of the
nation's priorities for its
environmental programs? Would
such an approach contradict the
will of the people? And do
scientific uncertainties alone
pose a substantial enough risk to
discourage Congress from taking
such action?
  Consider first whether the
public will or welfare would be
contradicted by revising the
nation's environmental priorities
through a risk-based approach.
  It's notable that despite a
proliferation of environmental
laws and regulations—and
evidence of improvements in
environmental quality over the
last 20 years—public concern over
the damaging effects of pollution
continues to mount. Opinion
polls repeatedly indicate that a
majority of the public feels that
environmental quality is
declining and that health and
ecological risks from pollution
are on the increase.
  Obviously, the public is not
happy with the status quo. While
the public appears to be growing
increasingly disenchanted,
environmental expenses, now
estimated at $100 billion yearly
or approximately two percent of
the nation's GNP, continue to
escalate. Although a reordering of
the environmental agenda is
unlikely to reduce environmental
costs significantly in the short
term, I would point out that  these
increasing costs are drawing the
public into a growing national
debate over the government's
effectiveness in protecting the
  Despite differences of opinion
between the public and
environmental experts over the
allocation of resources, I'd also
emphasize that the United States
already  has in place several
important environmental statutes
of high caliber.  A big problem
with these statutes is that they
have never been prioritized in
any systematic manner. Rather
they have been enacted, one after
another, more or less in response
to crisis situations.
  Using comparative risk analysis
as a mechanism to prioritize the
nation's agenda would not
necessarily result  in a major
restructuring of our existing
environmental laws and
programs. Nor would it diminish
the public's strong environmental
commitment. It would require the
public to become much more
knowledgeable about the relative
seriousness of the nation's
problems. And comparative risk
analysis would enable legislators
and regulators to fine tune
existing environmental laws and
programs so that they function
more effectively.
  Concerning the scientific
uncertainties associated with risk
management, I would point out
that risk management, as
distinguished from risk
assessment, is not, nor does it
make  any claims to be, a science.
Rather it entails the use of
science  as a factor in making
subjective policy and budgetary
decisions. For the purposes of
setting basic environmental
priorities, absolute scientific
precision generally is not
attainable. Reliable, accurate
information to allow for a general
comparative ranking is all  that is
  Setting environmental and
other  policies  involves reviewing
choices, setting priorities, and
making  hard decisions. When
everything is a priority, nothing
is a priority. In a time when the
world's  natural and economic
resources are under growing
strain, it is my belief that
Congress, and  by  implication the
EPA, will continue their progress
toward finding improved
solutions to the nation's
environmental problems. Risk
management should, and will,
play an  increasingly important
role in these efforts.
                                                                                                         EPA JOURNAL

Don Ritter
(R-Pennsylvania) is
ranking Republican
member of the House
Subcommittee on
En vironm en t.)
   Last fall, the EPA's independent
   Science Advisory Board (SAB)
issued the Reducing Risk report,
which recommended that EPA
deal with environmental hazards
based on the severity of risks to
human health and the
environment. Administrator
Reilly has stated that EPA should
pursue a "worst first" policy.
This makes sense, but how can
the Agency make it  work in
  Think of EPA as a company
attempting to change its business
plan in response to  reports that
say times have changed. The
research department's director
says the company should rely
more on new products  his
department is testing. He warns,
however, that tests to assess these
products aren't foolproof.
Unfortunately, the researchers
spend most of their time and
resources fixing problems with
current products. There's another
problem: The company is almost
broke. There's no choice for the
foreseeable future but to service
and sell the current product line.
  This is an approximation of
EPA's current dilemma. In 1970,
the new Agency tackled
traditional smokestack  and
end-of-pipe controls. Twenty
years  later, it must address more
complex situations, such as
pollution-source reduction and
disparate non-point or  "area"
sources. EPA must adapt to the
changing needs of environmental
protection, or serious problems
will go unsolved. The Agency
should decide which hazards  to
address first, based  on  scientific
  As in the corporate world,
there are scientific and financial
issues. Risk assessment, the
science of modeling risks to the
environment, is still relatively
new. EPA scientists spend the
bulk of their time providing
technical support for activities
under major environmental
statutes, such as the Clean Air
Act. For this reason it's difficult
for the Agency to consider
research, let alone new regulatory
programs, in other fields where
risks to the population may be
higher. Of course, in the current
federal budget climate, funds are
scarce for all research activities.
  Some risk assessment models
are well developed,  and the
magnitude of certain hazards is
established. EPA's program
offices, however, do an
inadequate job of understanding
risk assessment methods and
integrating them into regulatory
decisions. The Agency must do a
better job of meshing science and
  Here are three specific
recommendations to help the
current situation by moving the
Agency toward a risk reduction
• Develop stronger risk
assessment criteria.  EPA should
improve  the accuracy and
consistency of risk assessment
methodologies. At the March 12
hearing of the Subcommittee on
Environment on the FY 92
budget request for EPA's Office of
Research and Development
(ORD), Dr. Robert Huggett  of the
Science Advisory Board (SAB)
testified that data gaps remain in
key areas, including adequate
evaluation of impact on
ecosystems and human exposure
to pollutants. ORD's research
activities could narrow these
• Improve cooperation between
researchers and program offices.
Too often, the program offices
view science as a mere input into
the regulatory process. There
should be more feedback between
scientists and regulators, with
regulatory decisions made in
tandem with scientific advances.
ORD should upgrade its efforts,
through its Risk Assessment
Forum, to apprise the program
offices of significant
developments in risk assessment
practices. Finally, enhanced
training for program office
scientists will bolster their
understanding of proper risk
assessment protocols.
• Modify the budgetary process.
At the March 12 hearing, ORD
Assistant Administrator
Bretthauer described a pilot
program to incorporate risk-based
concerns in the budgetary
process. Of course, Congress
continues to mandate actions
based on considerations other
than a "worst first" approach.
That is the current reality of
environmental protection. Still,
EPA will have considerable
latitude to implement a "worst
first" approach.
  Risk-based budgeting is an idea
whose time has come. I support
this activity and hope it spreads
through the entire Agency. The
upcoming debate over
reauthorization of the Resource
Conservation and Recovery Act
(RCRA) affords a good
opportunity to incorporate
concepts of risk-based budgeting.
As the SAB has demonstrated,
solid waste issues present a
relatively low risk to human
health and the environment
compared to other environmental
hazards. Yet the public is avidly
interested in these issues. The
challenge for Congress will be to
address legitimate public
concerns, while optimizing the
limited resources available to
EPA and the private sector.
  In an era of relatively static
fiscal budgets, the environment is
not well served by  forcing
cleanups and management
standards for solid  waste  far
beyond the point of diminishing
returns.  A risk-based, "worst
first" policy of setting priorities,
with greater consideration of
costs to the public and private
sectors, will yield substantial
benefit to public health and the
  When good science forms the
basis for good regulatory policy,
EPA will have come a long way
toward fulfilling its mandate to
promote a healthy

Mark Sagoff
(Sagoff is Director of
the Institute for
Philosophy and
Public Policy at the
University of
Maryland at College
 In the United States during 1987,
 1988, and 1989—the most
recent years for which the FBI
has published statistics—no one
was killed or  injured as a result
of a terrorist attack. In the same
period, lightning killed more
than 200 Americans.
  We worry more about
terrorism, however, than about
lightning. We accept the risk of
being struck by a lightning bolt
in a way we never could accept
the risk of being hit by a terrorist
bullet.  This is because terrorism,
besides endangering individuals,
violates our moral intuitions and
expresses contempt for the
principles on which civil life is
  In the regulation of risk,  safety
is not our only goal, and it may
not even be our principal
concern. We are also concerned
about man's inhumanity to man.
We rightly spend more to reduce
comparatively small risks that
outrage us than to reduce larger
risks that occasion no  such
resentment. The acceptability of a
risk may depend less on its
magnitude than on its meaning.
  Oil spills, hazardous wastes,
leaking underground storage
tanks, ground-water
contamination, and the release of
radioactive materials: Each of
these may pose less danger to
public  safety  and health  than, for
example, radon; nevertheless
they occasion more resentment.
A naturally occurring  danger in
no way violates our intuitions
about how we should  treat each
other. By contrast, negligent
handling of hazardous waste
outrages  us even if the damage it
does is comparatively  small.
  The Scientific Advisory Board
(SAB) report urges EPA to  "target
its environmental efforts on the
basis of opportunities  for the
greatest risk reduction." This
reasonable suggestion  may lead
EPA to spend more, for example,
on indoor air pollution and less
on hazardous waste.
  While applauding this
suggestion, one might point out
that the laws EPA enforces
express many of the same moral
and social principles we find
embodied in criminal and in
common law. The purpose of
punishing criminals is not simply
to deter crime; it is also to
enforce the rule that we should
not harm each other without
justification. Likewise, the
common law of tort—as we see
in the recent Supreme Court
decision to uphold punitive
damages—vindicates community
standards concerning the care a
reasonable person should exert to
protect the interests of others.
  The SAB aptly observes that
"EPA should attach as much
importance to reducing ecological
risk as it does to reducing human
health risk," in part because
"natural ecosystems ... are
intrinsically valuable." If EPA
may vindicate the public's
perception that ecosystems are
intrinsically good, the Agency
may also vindicate the public's
perception that certain kinds of
pollution are intrinsically bad.
The Agency has statutory
authority to penalize instances of
environmental irresponsibility
which criminal and common law
have yet to reach.
  The SAB sensibly instructs
EPA to improve the scientific
methodologies "that support the
assessment, comparison, and
reduction of different
environmental risks."  The
Agency should also analyze the
moral principles that allow us to
understand the meanings of
different risks—to comprehend
why we resent lightning, for
example, so much less than we
resent terrorism.
                                                                                                        EPA JOURNAL

               FORUM  TWO  — THE SCIE]
               Dp  We Know Enough to Take  a
               Risk-Based Approach?
                D. Warner North
                (North is Director of
                Decision Focus, Inc.,
                a consulting firm in
                Los Altos, California.
                He is president-elect
                of the Society for
                Risk Analysis.)
   Estimating risk is a process for
   summarizing science to support
decision making. Protecting the
environment involves managing risks,
and it requires judgment about what
we want to protect and how
important it is to protect it. What the
risk manager wants from the scientist
is  an assessment of the level of  harm
and how likely the harm is to occur.
So making risk estimates is a way to
have clear and concise
communication from scientist to
decision makers, and to those who
are interested in and affected by
environmental protection decisions.
Quantification of risk facilitates
comparisons among action
alternatives and between problem
areas. Even qualitative judgments
about risk may be useful as a means
of summarizing scientific judgment.
  Labeling of risk estimates is
critical. For example, EPA's cancer
risk numbers are described in the
Agency's 1986 Guidelines as ... "a
plausible upper limit to risk
consistent with some proposed
mechanisms  of carcinogenesis ....
The true value of the risk is
unknown, and may be as low as
zero." Without this clarification,
EPA's cancer risk numbers might be
mistaken for  relatively precise
estimates of cancer deaths resulting
from exposure to toxic substances,
similar to the risk estimates for
deaths from highway accidents. The
two sets of risk numbers are of a
different character. Risk estimates  for
highway deaths are based on
extensive statistical data. For most
chemical carcinogens such statistical
data do not exist; EPA's cancer risk
numbers are extrapolations from
high-dose animal experiments, made
using a standard procedure in order
to  project the highest plausible level
of  human cancer risk. Most cancer
risk numbers reflect risks that are
highly uncertain and which could be
zero, whereas the highway risk
estimates reflect risks that are,
unfortunately, predictable with high
  Even if properly labeled, a single
risk estimate may not be adequate.
For important decisions, the
responsible decision makers will
want to know more. They will want
to have a narrative that describes the
most important scientific
information, the methodology used to
estimate the risk, a description of
important uncertainties, and answers
to "what-if" questions to ascertain
how risk  estimates would change if
different methods or assumptions
were used.
  Risk estimates should be critically
reviewed for the methodologies
employed, the scientific data used,
and judgment of experts used in
preparing the estimates. Scientists
often disagree. Risk estimates can
illustrate  the extent of a disagreement
and help  decision makers to assess its
  Estimates of risk can  sharpen
debate about how to manage our
environment. They help
communicate what science can tell
us about the possible harm to the
environment of various activities.
Estimates of magnitude and
likelihood help us comprehend the
possibility for harm. Further, they
can help to clarify areas of
uncertainty and to evaluate the
importance of scientific
disagreements. They can help EPA
and other regulatory organizations to
be more consistent and  more efficient
in using finite resources to
implement environmental protection
policy. However, they cannot resolve
controversies over how  much should
be spent to protect the environment
or which aspects of the environment
are most in  need of protection.

     Paul Deisler
     (Dr. Deisler is a
     retired official of the
     Shell Oil Company.)
         To this question, the two-handed
         scientist—that bane of the
      manager who dearly wants the one
      right answer—will stand up and say:
      "On the one hand, yes; on the other
      hand, no." And I have bad  news for
      that manager: The scientist can  be
      right, either way.
       Which way the answer goes
      depends a  lot on the willingness of
      both managers  and scientists to
      understand and accept the  current
      limitations of knowledge, the gaps
      and uncertainties in it, and the  fact
      that new knowledge often changes
      what we thought we knew. They
      must realize that any risk-based
      ranking of  environmental programs is
      provisional. If they do, and if they are
      willing to accept not only factual data
      but scientific best judgment and
      opinion as part of the ranking
      process, the answer comes  up "yes."
       Ranking  is useful to a risk manager
      even if it is uncertain, provisional,
      and temporary, even if it is cast into
      doubt the next time a research paper
      is published or a new thought is
      expressed.  Both managers and
      scientists must learn to live with
      change, to  cope with uncertainty and,
      at the same time, to encourage and
      help bring  about the increase in
      knowledge and understanding. They
must be flexible, ready to revise
today's best thinking. I know this
from my own experience, and I've
always been happy to accept the best
current scientific opinion as an
ingredient in my thinking, to use it
carefully in light of the cautions
I've been given.
  After all, if the best, current
scientific opinion is not the best
guidance about a deeply scientific
matter, what is?
  Managers and scientists alike  also
need to  understand that a risk-ranked
program list is not a priority list.
Other considerations than risk help
form a priority list. They  include
timing; technical and economic
feasibility; the urgency of action for
each program;  and the fact that, in
any one year, there is a limit to  how
much money and effort is available.
  It is very important for managers to
reassure scientists that their rankings
will be accepted and used in the
proper spirit, and that their concerns
about uncertainty and incomplete
hard information will not be
disregarded. Scientists, in turn,  must
assure managers that they have  done
their best to arrive at the best answer,
that they have followed a logical
process  of assembling, assessing, and
considering all  available information,
judgments, and opinion, and that
they have defined and used
reasonable criteria.
  Also,  even with the best will and
understanding in the world, there
may exist so little basis to support
opinion or judgment in some cases
that particular programs can't be
ranked against others. Here, the
unrankable programs stand as signs
pointing to the  need for information,
and they should be given a priority
ranking, as opposed to a risk-ranking,
based on other factors I've already
mentioned. The whole risk ranking
exercise serves to point out just
where more knowledge is critically
needed  to do the job better.
  So my answer to the question is
"yes," if the ranking is done and used
with the understanding that, like the
weather report, it is a form of interim
guidance and not a guarantee. Don't
wait for the millennium. Start now,
get better as you learn what you need
to know, and get on with the job of
managing risk.
Frank Mirer
(Dr. Mirer, a
toxicologist and
industrial hygienist,
is Director of the
United Auto Worker's
Health and Safety
  Phe question of whether science
  I should be used for setting
priorities and allocating resources for
environmental programs implies that
currently it is not, and that efforts are
disordered. In fact, scientific
knowledge is incorporated into
existing legislation and regulation.
However, the ultimate authority must
remain with the public, and policy
makers must represent the public's
  The recommendations of the
Science Advisory Board (SAB) that
EPA should do more about ecological
endpoints, such as global warming,
habitat destruction, loss of biological
diversity, and acid rain, have merit.
So do their recommendations that the
Agency pay more attention to the
health effects of ambient air
pollutants and worker exposure to
chemicals. However, this doesn't
mean that EPA should  do less about
hazardous waste, pesticide residues
in food, and problems related to
exposure to toxic chemicals.
  The board's claim that reordering
priorities on the basis of risk analysis
will result in more cost-effective use
of resources is highly suspect. Not
only does the science of risk
assessment, itself, have a way to go,
the practice of estimating costs of
                                                                                                        EPA JOURNAL

environmental and occupational
health protection, thus far, at least,
has proven to be an abject failure.
Most often it has been advocated by
ideologically conservative economists
who have never worked at the
"bench" of financial analysis or
subjected their methods to systematic
  The present framework of laws and
regulations is the result of a collision
between current scientific knowledge,
industry resistance, and public health
agency inaction. Where  action is
taken, it is limited to areas where
there is apparent precision in
expressing risk. Issues such  as the
stench of some  factories or the
clear-cutting of forests, where the
outcome can't be expressed  as a
number, are neglected.
  Science won't be helpful in at least
two areas  of priority setting. Science
can't compare risks that have
ecological end points with those  that
have health endpoints, and ecological
concerns are often denigrated by
limiting public  intervention to those
matters which cause disease and
death. Even within the health sphere,
scientists can't always help. How are
they to decide between high risks to
small groups (pesticide applicators)
and smaller risks to large groups
(pesticide residues)? How are they to
evaluate low probability/high impact
catastrophes (nuclear  power plants)
against exposures that are deferred
and therefore less predictable (buried
toxic waste)?
  New science confirms the wisdom
of past legislation, but it also
demonstrates the need to
reemphasize previous concerns for
both health and the environment. We
should not allow claims of reordering
priorities to camouflage the  dropping
of existing protection  programs.
Gilbert S. Omenn
(Professor Omenn
(M.D., Ph.D.) is Dean
of the School of
Public Health and
Community Medicine
at the University of
Washington in
   Formal risk assessment by the major
   regulatory agencies emerged only
in the past 15 to 20 years. In my
opinion, the framework that has
evolved is very helpful in organizing
both the scientific gathering and  the
scientific interpretation of
information as part of the decision
making process. The actual decisions
rest upon statutory requirements and
political, economic, and social
  The recent effort by EPA and its
Scientific Advisory Board (SAB)  to
use estimates of risk to order
priorities is a bold and logical step
forward from that of assessing
individual chemicals. There is no
doubt that such an approach could be
applied to a set of pesticides with
similar desirable and similar adverse
effects. Similarly, a combination  of
quantitative risk estimates and
weighting for severity of effects
would help inform the priority
setting among criteria air pollutants
and air toxics, both indoors and
  The SAB effort to embrace
ecological as well as health risks was
just a start, exposing the need for
"rules of thumb" or "equivalences"
across such disparate effects. It was
an important affirmation that we
want to protect both health and
environment, that reduction of
emissions will have benefits in both
  If this effort at relative risk
assessment can help ecologists and
environmental health specialists
communicate with each other,
perhaps we can break down the
barriers between them. These
scientists earn their degrees in
different colleges, attend different
meetings, publish in different
journals, speak and write in different
jargon, and know rather little about
each other's problems. Priority-setting
exercises can bring them together
within EPA and the counterpart
agencies in the states and in
universities and industrial and
environmental organizations as well.
Priorities are set all the time on
political and budgetary grounds; the
new approach explicitly  asks what
science can bring to the table.  I am
confident that scientific data and,
equally, the scientific method can
bring a lot to these decisions and can
help bridge the gulf between
scientists and the public  at large.
  Administrator Reilly's  testimony in
January 1991 before the Senate
Committee on Environment and
Public Works set just the right tone.
We need to make existing laws
workable. We need to find
convergences of our environmental,
economic, and energy goals. And we
need to convince a skeptical public
not only that we are attacking the
worst problems first, but  that we
know how to move on to other
serious problems, when risks
identified earlier have been reduced.

     Paul J. Lioy
     (Professor Lioy is
     Director, Exposure
     Measurement and
     Assessment Division,
     University of
     Medicine and
     Dentistry of New
        Estimating the risk of an
        environmental pollutant depends
     on our ability to measure both the
     human exposure to the pollutant and
     the hazard. My experience has
     focused primarily on exposure; it
     illustrates some of the problems
     encountered when attempting to set
     environmental priorities on the basis
     of risk.
       The fundamental problem in
     assessing exposure is the paucity of
     baseline data on human contact. For
     many pollutants, the data are weak or
     incomplete with respect to personal
     contact, measurements for different
     routes (for example, inhalation or
     ingestion), and identification of the
     activities which affect contact.
       The lack of such data  should be of
     no surprise, since there  is no national
     research program on human exposure
     with funds dedicated to basic and
     applied research. In the  current EPA
     Office of Research and Development
     budget, only $6.7 million is
     dedicated to exposure, which
     represents IB percent of the  total EPA
     research budget on human effects.
       This level of effort contrasts with
     the ones in toxicology that form a
     major part of the data bases used in
     hazard assessment. For example,
     within the National Institute for
Environmental Health Sciences, the
contribution to the National
Toxicology Program is $72 million,
and funds are committed for 4,000 to
6,000 extramural environmental
health research projects per year.
Few, if any, are devoted to human
exposure. Obviously, there is a need
for concerted efforts to substantially
increase the funds available for
applied and basic research on
exposure. The results will provide
the data bases necessary to "truly"
prioritize national risk problems.
  The data currently available for use
in an assessment are frequently
derived from measurements made in
air, water, soil, or food. Normally, the
measurements were not made for the
purpose of defining actual human
exposures.  These  data are only useful
for identifying the range of exposure,
since measurements in multiple
media are not usually made at the
same time and place. Further, the
places for which data are available
may  not be representative of the
locations where the high exposures
actually occur. Unfortunately, these
data  have been used to identify a
Theoretical Maximum Exposed
Individual, a poor soul who, it is
assumed, spends his or her 70 years
of life in direct contact with the
pollutant all day long. These types of
estimates can lead to an over
estimation  or under estimation of the
actual exposure. If, eventually, we are
able  to greatly improve our databases
on those  human activities likely to
cause exposures, and quantify the
actual contact with a contaminant for
one or more routes of entry to the
body, we will be able to prioritize
many environmental risks.
  There are encouraging signs that
opportunities for exposure
assessment to play a critical role in
establishing a scientific basis for
prioritizing environmental risk will
improve. Included are the EPA
Exposure Assessment Guidelines,
which convey the idea of prioritizing
problems by multimedia pathways
and routes  of contact, and the
National Research Council's report on
Air Pollution Exposure Assessment,
which provides a  scientific
framework  for conducting basic and
applied research on total human
  Finally, there is another factor to be
considered. All environmental risks
cannot have the same level of societal
response. Some are long-term
problems; others are short term. The
overall impact of some long-term
problems can be devasting to
mankind (stratospheric ozone, for
example), but their solution requires
a major international commitment.
Other problems may be more
immediate, or of smaller scale, and
still require high priority for risk
reduction (tropospheric ozone or
environmental lead).  We can affect
the latter using the strategies
developed within our country.
Consideration of this factor might
lead to the identification of  categories
of national environmental risk.
  William  Cooper

  (Dr. Cooper is a
  professor in the
  Department of
  Zoology and the
  Institute for
  En vironm ental
  Toxicology at
  Michigan State
     Like all models, risk assessment
     models are abstractions of reality.
  Are current risk assessment models
  sufficiently developed to aid in
  environmental decision making?
  Pragmatically speaking, the answer
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depends in large part on what are the
  My response to this question will
focus specifically on ecological risk
assessment. Ecological models have
been tested empirically, in the real
world, for decades. Pest management,
watershed management, farm pond
aquaculture, and game and landscape
management are all examples of the
practical applications of ecological
  The best examples of ecological
risk assessment, using models that
forecast future events, are found in
Environmental Impact Statements
required under the National
Environmental Policy Act (NEPA).
For the purpose of Environmental
Impact Statements, NEPA requires
that we anticipate positive and
negative environmental impacts years
into the future. At the same time,
these requirements are sufficiently
flexible to allow the integration of the
"best professional judgments" of
scientists from many diverse
disciplines. Thus, it is a mistake to
think that the only risk assessment
methodologies available are those
employed by toxicologists in
assessing the impacts of carcinogens
in humans.
  Existing ecological models are not
precise, but they are logical,  they
integrate findings from various
disciplines, and they are prospective.
Our society cannot wait until the
models are perfect before committing
monies, energies, and human
resources toward  mitigating potential
threats to the environment. Most of
us won't live long enough to observe
if we over- or under-react to
environmental problems. We  have to
make commitments today, and our
grandchildren will perform a post
mortem on our logic.
  The need for proactive decision
making is  clear when you consider
what is at stake. Moreover, I would
rather gamble on  the instincts of field
scientists who manage landscapes
than those of lawyers, statisticians,
and economists. At least the
projections of the former are regularly
tested against the natural laws of
thermodynamics and evolution.
Stanley Auerbach
(Auerbach is Director
Emeritus for the
Sciences Division of
the Oak Ridge
National Laboratory.)
   The science of risk analysis is a
   quantitative method of generating
a probability of the occurrence of
some undesirable event. Risk
estimation is a judgment based on
experience, perception, or similar
intuitive approach. Combining the
two poses a dilemma. Current
"estimates" of many environmental
risks may embody too much
variability or uncertainty for them to
be relied on in setting priorities or
allocating resources.
  To define risks scientifically,
whether they be environmental or
health risks, we must first define the
endpoint: in other words, what is at
risk? Society generally accepts
cancer, injury, or death as endpoints
for human health risk analysis.
However, we do not as yet agree on
ecological endpoints that can be used
in quantitative risk analysis.
  Currently, we spend billions of
dollars cleaning up environments
that have been contaminated by
accidents or by the disposal of
wastes. Municipal landfills,
hazardous waste disposal sites,
formerly used industrial facilities,
and defense installations are
undergoing massive and
unprecedentedly expensive clean-up
efforts. Oil spills and chemical
releases, whose impacts are
immediate and more dramatic, also
call for large outlays of funds.
Further, such accidents may have
long-term consequences for
  For many, if not most, of these
clean-up efforts, the presumed risks
to health and the  environment are
based on limited scientific data and
analysis. There is definite lack of
knowledge as to the degree of
uncertainty surrounding the
assessment of risk. Here is where
science  is needed. Science can
incorporate the degree of uncertainty
that may become  evident during the
risk assessment process, whether it
be short- or  long-term risk. Priorities
can then be  set to direct needed
research programs.
  My answer to the question posed in
this forum, then, is yes, provided we
combine quantitative risk assessment
with a formal uncertainty analysis,
which is a mathematical measure of
the degree of confidence in the
prediction of risk. Uncertainty
analysis becomes  a powerful tool
because, in addition to measuring
this degree of confidence, it can
identify the  sources that contribute to
the uncertainty. It can, therefore,
guide us in allocating resources to
bring perceived risks closer to actual
risks in  dealing with environmental
issues. Lastly, it can help improve the
public's understanding of risk in an
absolute and relative sense.

     Mark A. Harwell
     (Harwell is Associate
     Professor at the
     Rosenstiel School of
     Marine and
     Atmospheric Science
     at the University of
         Clearly, we know that the health of
         our environment is being
     significantly affected by a host of
     human activities. But  there are
     substantial uncertainties in our
     present understanding of how
     ecosystems work. What is natural
     ecological variability over time and
     space? What is the nature of human
     stresses on ecosystems? How  do
     ecosystems respond to stress? There
     are many other areas.
       The environment, and human
     impacts on it, are so complex that
     there will always be uncertainties,
     but that does not mean we  know
     nothing about the environment. We
     can and must make environmental
     decisions in the presence of
     uncertainties. Research and
     experience over time will increase
     our ability to predict ecological
     effects of human activities  and thus
     assign risk more accurately. However,
     prioritizing major environmental
     problems, to show where efforts
     would be most effective in protecting
     the environment, only requires
     assessing relative risks, not
     calculating precisely the absolute
     values of risk. This makes the task
     much easier and well within  the
     present state of scientific
     understanding of ecology.
  Through the EPA Science Advisory
Board's relative risk project, we
developed ways to assign relative
risks for a broad diversity of
environmental problems by first
listing categories of ecosystems and
dividing environmental problems
comprehensively into categories of
stresses. Then we systematically
estimated how widespread each
environmental stress is, how much
and what kind of ecological damage
it may cause for each ecosystem type,
and how long it would take for the
ecosystem to  recover. By looking
across ecosystem types and across
scales of space and time, we were
able to collapse all that information
into an organized listing of what
environmental problems are of
greatest risk (e.g., global climate
change, habitat alteration, species
extinction and loss of biodiversity,
and stratospheric ozone depletion) as
distinct from  those problems of much
more  limited  concern (e.g.,
radionuclides in the  environment, or
thermal pollution). That is not to say
that radionuclides  are of no concern,
or that thermal pollution may not  be
important in  some locations, just that
their overall ecological risk is much
lower than  the risk from climate
change or tropical  deforestation.
  Yes, there are uncertainties. No
one, for example, can yet say
defensibly just where climate change
will cause the greatest impacts or
precisely what level of species
diversity is necessary for ecosystems
to be  healthy. It is  very important
that ecological research address these
and many other environmental
questions so that we may continually
reexamine and improve our estimates
of risk and  anticipate new threats  to
the environment. Nevertheless, our
scientific understanding of ecology
today is sufficient  to begin the
relative risk-ranking  process,
sufficient to set priorities across
major categories of human activities,
and thus sufficient to allocate
resources in a way that is in concert
with real ecological risks. In other
words, we know enough that we
don't have to just respond to the
latest environmental crises or to
popular perceptions  of risk.
John D. Graham
(Graham is Director
of the Center for Risk
Analysis of the
Harvard School of
Public Health.)

I n order to recognize the virtue of
I comparative risk analysis for
environmental policy, it is instructive
to consider the politics of resource
allocation. Additional resources are
needed to address numerous problem
areas: toxic air pollution, endangered
species, carcinogenic pesticides,
smog in the cities, hazardous wastes,
global warming,  nonpoint-source
water pollution,  wetlands protection,
and so forth.
  Each problem  area has a political
constituency  which exists inside
EPA, in various congressional
committees, in the mass media, in the
consulting and research communities,
in private industry, and among
environmental advocacy groups.
Without comparative risk analysis,
the claims of these constituencies for
expanded resources are made
independently, often without
adequate review of their plausibility.
  If the American people are willing
to write a blank  check to pay for the
cost of environmental policy, then
there is no  resource allocation
problem. But there is no blank check.
As my colleague Paul Portney has
argued, environmental expenditures
should be scrutinized because our
nation has  numerous other needs that
require expanded resources. They
include deserving causes such as
education,  AIDS research, health care
insurance, traffic safety, family
violence, space exploration, and the
military capabilities that were
                                                              EPA JOURNAL

recently demonstrated in the Persian
Gulf. Congress limits EPA's budget
precisely because the American
people and interest groups pressure
their elected representatives to meet a
wide range of compelling needs.
  Faced with conflicting claims for
access to limited resources, EPA has
recently turned to its Science
Advisory Board  for help in the
priority setting process. Rather than
rely solely on political negotiation to
establish budgetary priorities, EPA
has sought some advice from
independent scientists about which
environmental risks are the most
serious and  which can be reduced
most efficiently.
  SAB's message, which has
generated celebration and alarm
among political constituencies, is that
relatively more attention should be
focused on global and ecological risks
while relatively  less attention should
be given to speculative health threats
such as the current and future risks
of hazardous waste. It is refreshing
that EPA and Congress are open to
the views of scientists about the
allocation of scarce national
  The only danger in this  process is
that some citizens may be deluded
into thinking that comparative risk
analysis is a purely scientific
undertaking. It is not. Risk
assessments, while useful, cannot
usually offer policy makers a  high
degree of precision. The more
fundamental point is that judgments
must be made about tradeoffs
between cherished values, such as
protection of public health and
preservation of ecosystems. Even
within the domain of human health,
value judgments must be made about
the  relative importance of cancer and
noncancer health effects (e.g.,
neurological effects).
  When the  EPA Science Advisory
Board offers advice  about
comparative risk, it must be—either
implicitly or explicitly—making
sensitive value judgments. The board
should articulate the limits of its
scientific knowledge and the nature
of the value judgments that it is
making. IF EPA and/or Congress
disagree with the SAB's comparative
findings, they can ignore them.
 Nancy Kim
(Dr. Kim is Director
of the Division of
En vironm en tal
Health Assessment at
the New York State
Department of
    Despite many uncertainties, the
    science of estimating risk can be
used to help order priorities and
allocate resources for environmental
programs. The best science available
should be used for these purposes.
However, the limitations of risk
assessment need to be understood
when using it for decision making of
any kind. In particular, it is
important to consider the
assumptions that underlie risk
assessments and the frequent data
limitations in such areas as
toxicology and exposure.
  Broadly speaking, human health
risk assessments are based on two
major components: toxicology, which
evaluates the inherent toxicity of a
chemical substance; and exposure
assessment, which estimates the
extent to which people may actually
be exposed to  the substance. In many
cases, our knowledge about the
toxicology of a chemical, its potential
adverse health effects, is incomplete
or lacking.
  The Chemical Abstract Service has
assigned registry numbers to some 10
million chemicals. Roughly 70,000
chemicals are  used in commerce;
fewer than 10,000 have some health
effects data; and about 100 have some
direct human data. Certainly these
data limitations are formidable.
Moreover, it is important to set
priorities for testing chemicals for
adverse effects by considering
available information on use patterns,
potential exposure patterns, and
similarities among chemicals.
  Exposure data gaps may be even
more problematic than gaps in
toxicology data. Historically, much
more emphasis has been placed on
obtaining toxicology  information than
on acquiring exposure data. This
situation is beginning to change and
more attention is being paid to
exposure considerations. For
example, emissions data now being
compiled under  the Toxic Chemical
Release inventory required under the
Superfund Amendments and
Reauthorization  Act of 1986 can be
used to identify  potential exposure
problems. Monitoring studies may
then be conducted to obtain
necessary exposure data.
  Efforts to gather  monitoring data
are increasing, but they are still
sporadic. EPA is establishing
additional monitoring requirements
for drinking water, which  will help
characterize exposures through
drinking water. The Food  and Drug
Administration routinely monitors
foods for pesticide residues, but food
is not normally monitored for the
presence of common industrial
chemicals. Our understanding of
exposure to  chemicals through
incidental ingestion of dust and dirt
has greatly increased, but is still
limited. In short, we  have a long
way to go in exposure assessment.
  In addition to  data limitations,
there are uncertainties inherent in
standard risk assessment procedures,
which typically involve extrapolating
from test animal data to human
exposure scenarios. The science of
risk assessment is imperfect;
however, we should  use as much
science as possible in setting
priorities and allocating resources.
Otherwise, our options are to rely on
what people believe,  intuitively, is
important, on the public's worst
fears,  or on political  interests. These
other aspects and technology should
be considered in decision  making,
along with risk assessment.

    Adam M. Finkel
    (Finkel is a fellow at
    the Center for Risk
    Management at
    Resources for the
        Risk-based environmental policy
        has its pitfalls, to be sure, but to a
     large extent the faults "lie not in the
     stars, but in ourselves."
       I am optimistic that risk assessment
     could provide a far more helpful and
     less divisive instrument than it now
     does. Ironically, we are asking too
     much of risk assessment, while at the
     same time failing to exploit all that
     the existing science has to offer. If I
     had to choose one improvement
     (requiring no new scientific
     breakthroughs) that would  make risk
     assessment more useful while
     revealing its limitations, I would
     require risk assessors to quantify and
     communicate the uncertainties
     inherent in  their risk estimates.
       Let me illustrate this point with a
     simple example of priority-setting.
     Suppose that (before EPA prohibited
     the spraying of Alar on apples) you
     were a consumer trying to decide
     whether apple juice or peanut butter
     contaminated with aflatoxin, a
     natural carcinogen, was more
     dangerous to you personally, or more
     worthy of federal regulatory
     intervention. Perhaps you had read
     about the comparative risk
     assessment  Dr. Bruce Ames
     performed on a  variety of natural
     versus synthetic carcinogens, from
which he concluded that the
aflatoxin in a daily ration of peanut
better is 18 times as risky as the Alar
in a daily ration of apple juice.
  The degree of false confidence
implicit in that kind of "point
estimate" of risk is simply staggering.
By comparison, using widely
accepted methods to account for at
least some of the major uncertainties
in the toxicology of those two
chemicals and in human exposures to
them, I estimate that a randomly
chosen consumer could be only 90
percent sure that peanut butter is
between 300 times more and 30 times
Jess of a cancer risk than apple juice
is. The number 18 is not "wrong"  as
a relative risk estimate, but the
number alone tells about as much  of
the story as "In the beginning" tells
you about the Old Testament.
  Fortunately, comparative risk
assessment could help EPA tell the
whole story, as long as it tackles the
problems of uncertainty and public
preferences head-on rather than
obscuring them behind "cookbook"
risk assessment procedures and
generic assumptions about values.
Despite what people say, you can
compare apples and oranges. We do
so all the time,  both literally and
figuratively, by deciding what
characteristics matter to us, how we
value them, and how much of each
quality each choice is likely to offer.
When comparing things (like risks of
uncertain magnitude), additional
dimensions of uncertainty intervene:
An orange may taste better to you
than an apple, but, all in all, an
orange the size of a pea would be  less
satisfying than an apple as big  as a
basketball. So, in fact, comparative
risk assessment is even harder to do
well than the one-thing-at-a-time risk
analysis EPA has used up to now.
But using only one number for each
risk makes a hard task virtually
impossible  to perform systematically
and confidently.
  The sensible way for a person to
decide whether to consume peanut
butter or apple juice—or for EPA to
decide whether to transfer resources
from, say, the Superfund program  to
a radon reduction effort—is to
recognize and weigh all the possible
consequences of making the wrong
choice. In any decision scenario, the
possibility that the seemingly smaller
risk might in fact be more dangerous
than the "larger" risk should lead the
decision maker to scrutinize very
carefully the component factors that
go into the decision, particularly the
uncertainties and variabilities
associated with them.  (In the
example above, I estimate there is a
one in three chance that apple juice
is in fact riskier than peanut butter.)
This would mean carefully
examining, for example, such
considerations as variations in risk to
different population groups (e.g., for
whom is apple juice or hazardous
waste more dangerous than peanut
butter or radon?), the nature of the
benefits that accompany the risks,
and the degree to which exposure
and risk may be voluntary or
  As the other forum in this issue of
EPA Journal makes clear, even the
most honest and  complete risk
assessment is a sterile  tool without
commensurate attention to the
non-quantifiable  social values that
supplement  or transcend  the mere
risk numbers. Moreover, comparative
risk management faces empirical and
quantitative  problems  not only in the
area of health science, but in two
other pillars of environmental policy
as well: cost assessment and risk
reduction solutions. The widespread
false precision in estimating the costs
of environmental regulation will
continue to impede the adoption of
effective policies. And the most
sophisticated ranking of risks and
benefits will be a vain exercise unless
EPA is committed to controlling even
the small risks when the solution is
cheap or economically beneficial and
dedicated to searching for new ways
to ameliorate what seem to be large
but intractable risks.
                                                               EPA JOURNAL

  Thomas A. Burke

  (Dr. Burke is with the
  Johns Hopkins
  University's School of
  Hygiene and Public
     From Love Canal to Bhopal, Prince
     William Sound to the Jersey
  Shore, environmental disasters have
  galvanized public opinion and
  shaped the country's environmental
  laws. Historically, the policies of EPA
  and state environmental agencies
  have been reactive in nature. Many
  priorities have been established in
  response to the crisis of the  day, with
  budgets driven by public opinion
  rather than public health. It  is  no
  surprise that the recent report from
  the EPA Science Advisory Board,
  Reducing Risk: Setting Priorities and
  Strategies for Environmental
  Protection, concluded that the
  amount of money spent  on
  environmental problems at EPA had
  little relationship to the level of risk
  posed by those problems.
    Properly applied, risk assessment
  can play an important role in
  improving the public-health basis for
  setting our priorities and targeting the
  efforts of EPA to reduce health and
  environmental risks. Over the past
  decade, risk assessment  has  evolved
  to the extent that it can offer
  scientists a common method to
  utilize information from the  fields of
  toxicology and epidemiology, to
  better understand potentially harmful
  environmental pollutants, to identify
previously unrecognized hazards, and
to estimate the degree of risk to
public health posed by many
pollutants. On both federal and state
levels, risk assessment has become a
pivotal component of the regulatory
process. Risk assessments have been
successfully used in establishing
drinking water standards and in
providing guidance for many of the
clean-up and pollution prevention
  To use risk assessment effectively
in setting priorities, policy makers
must recognize its limitations.  There
are many assumptions that have to be
made in measuring risk  that
introduce uncertainty. For instance, a
very basic assumption is that adverse
effects observed in laboratory animals
represent potential risks to humans.
For this reason, risk assessments
represent a range  of potential impacts
rather than a precise measure of
actual  effects.
  Risk assessment is also limited by
our lack of information regarding the
potential health effects of pollutants.
Only a small fraction of the
chemicals in our environment  have
been adequately studied for adverse
effects. This has led to the regulatory
equivalent of "looking for the keys
under the lamppost." The result has
been strict regulation of a small
number of cancer-causing substances,
such as asbestos and PCB's, but little
or no control of other substances
common in our environment which
may have other effects on health. For
example, despite widespread
concern,  little has been done to
control exposures which may cause
reproductive or developmental effects
or harm to the nervous or immune
system. To be successful in reducing
risks, EPA must commit itself to
filling the information gaps and
continually broadening our
knowledge of the  health effects of
environmental pollutants.
  Another serious limitation to the
use of risk assessments has been the
inability  of the scientific community
to communicate results to the public.
Confusing numbers, like parts per
trillion or one in a million,
compounded by press reports of
disagreement among the experts,
have undermined trust in science  and
the regulatory process. A
commitment to improve risk
communication is essential to the
success of risk-based priority setting.
  Despite the many limitations and
uncertainties, the science of
measuring risk offers a powerful tool
for priority setting. However, even a
flawless risk measurement cannot
define "acceptable" risk. Putting risks
in perspective and bridging the gap
between science and public policy
may be the most difficult challenge
facing EPA.  Successful priority
setting will ultimately depend on the
ability of policy makers to balance
risk measurements with public

What  the  Public  Thinks
by Thomas A. W. Miller
and Edward B. Keller
                                                                                       Changing public attitudes have
                                                                                        been the driving force behind
                                                                                          this country's environmental
        Americans' attitudes concerning
        most environmental issues are in
     a state of rapid and profound change.
     Whether we look at worries about
     pollution in general, or perceptions
     of the risks posed by specific
     problems, the recent shifts in public
     opinion have been little short of
       At the broadest level, the message
     being sent out by the American
     people is a clear one: We are
     increasingly nervous about the
     environmental problems around
     us—virtually any kind of
     environmental problem. Although the
     recession has somewhat dampened
     environmental concerns in the short
     term, as it has for education and drug
     abuse, the long-term trend toward
     heightened public sensitivity about
     environmental matters will continue.
       When examined in detail, however,
     the recent shifts in public opinion
     tell a much more complex and, at
     times, ambiguous story. This article
     will discuss current perceptions of
     specific environmental risks, changes
     in those perceptions in recent years,
     and the underlying attitudes driving
     public concerns. From the
     perspective of our public opinion
     research, we will also suggest some
     implications for public policy and for
     educational initiatives.

     (MilJer is Senior Vice President and
     Keller Executive Vice President of
     The Roper Organization, the public
     opinion research firm.)
How Americans View Environmental
In 1987. working with EPA, The
Roper Organization developed a
comprehensive list of 29
environmental problems. The
purpose was to rate the perceived
seriousness of these problems from
the public's point of view. These
ratings would then be compared to
scientific assessments of the risks
attached to these problems, as
determined by EPA's staff. A
benchmark measure was taken early
in 1988, and an update in early 1990.
Each time, the measure was taken of
nationally representative samples of
adult Americans, interviewed in
person in their homes.
  At the broadest level, these studies
illustrate vividly  how the concern
spreads to virtually all types of
environmental problems. Majorities
of Americans consider 28 of the 29
problems to be at least "somewhat
serious." They also call  17 of the 29
"very serious." Further, for 18
problems,  more people called them
"very serious" in 1990 than did so in
1988. This is a clear illustration of
the general growth of environmental
  Topping the list of most worrisome
problems, according to the  public, are
hazardous waste  sites, whether still
in use or already abandoned.  Nearly
two-thirds mention these as "very
serious." Also high on the list are
water pollution from industrial
waste, worker exposure to toxic
chemicals, accidental oil spills,
depletion of the ozone layer, and
radiation from nuclear power plants.
  At the opposite end of the
spectrum—the problems least likely
to be associated with high risk—are
radiation from microwaves and
X-rays, and indoor air pollution.
  Several points about how
Americans perceive the risks of
environmental problems are worthy
of note.
  First, they do perceive different
levels of risk,  whether or not their
perceptions coincide with those of
the experts. There is a significant
"spread" from the 67 percent who
consider active hazardous-waste sites
to be "very serious" to the 13  percent
who assign this rating to radiation
from microwave ovens. At the very
least, this spread suggests that the
capacity for public discrimination is
real—albeit sometimes, perhaps,
  Second, and more important, the
effect of language—how problems are
described to people—is clearly
evident. It comes as little surprise
that the two most serious problems
concern "hazardous" waste sites. To
say that a problem is "hazardous"
almost automatically raises a red flag
in front of the public.
  The potency of terminology is
clearly illustrated by a test Roper
conducted in its 1990 study of
                                                                                                      EPA JOURNAL


  specific risks. We used two different
  descriptions of the same problem and
  obtained different responses from the
  public. One nationally representative
  sample was asked about the
  seriousness of "solid waste created by
  people's litter and trash"; a different
  sample was questioned about
  "non-hazardous waste sites such as
  trash from households and industry"
  (the terminology we developed along
  with EPA for our 1988 benchmark
  measure). The first problem was
  considered "very serious" by 51
  percent, the second by only 31
  percent—an extremely large
    Even though both questions
  addressed  the same issue, solid
  waste, the inclusion of the phrase
  "non-hazardous" in the second
  description allayed the concerns of a
  very large  number of people.  If an
  environmental problem is called not
  hazardous, it is much less likely to be
  considered serious. Conversely, the
  use of words like "hazardous" or
  "toxic" will almost certainly increase
  public anxieties.
    Another interpretation is that
  "solid waste" is a familiar term, and
  the problem  hits close to home. In
  fact, in late 1990 nearly half the
  public said "consumer solid waste"
  was "very  serious" in their own
  community—double the level of
  concern only two years earlier. The
  proximity  of the issue, as well as the
use of common—not
technical—language to describe it,
helps explain the public's reaction.
  Finally, the public's ranking of
environmental problems differs in
major respects from the views of
experts. As discussed above,
hazardous-waste sites are considered
to be the most serious problems by
the public; the risks ascribed to them
by most knowledgeable authorities
 The effect of language—how
problems are described to
people—is clearly evident
are much lower. Similarly,
small—and declining—numbers of
Americans express concern about
indoor air pollution or radon; experts
consider these to pose relatively
significant risks to human health.
  In  some areas, public perceptions
are moving closer to expert
assessment. For example, the
proportion of Americans calling
destruction of the ozone layer a "very
serious" problem jumped from 47
percent in 1988 to 60 percent in
1990. The concern about the
greenhouse effect  also rose strongly
over this period: from 33 percent to
48 percent. In EPA's Science
Advisory Board report, Reducing
Risk, these are two of four high-risk
  Other changes in public opinion,
however, suggest that perspectives
are shaped more by media attention
to problems than by greater public
knowledge of their risks. Perhaps the
most dramatic illustration of this
phenomenon is the changing
attitudes about accidental oil spills.
In 1988, prior to the Exxon  Valdez
spill, only 38 percent thought oii
spills were a "very serious"
environmental problem. By 1990,
after the accident, the proportion shot
up to 60 percent. Oil spills are now
thought to be the fifth most serious of
the  29 environmental problems Roper
asked about, despite expert
agreement that they pose relatively
low risks to the environment and
human health.
  As memories of the Valdez
incident fade, and media attention
falls off, it is possible that public
worries about oil spills  may also
decline. Indeed, previous spills were
typically accompanied by upswings
in public concerns that  eventually
subsided. However, the Valdez spill
was  so massive that it may leave an
indelible imprint on public

            Continued on next page

Risk Communication
Unfinished Business, the EPA
report predating the Science
Advisory Board work, observed
that the attention the Agency
paid to problems didn't always
correlate well with the risks
posed by the problems. Not all,
but several problems posing
high risks received minimal
attention. Conversely, high
levels of funding were directed
at several low-risk problems.
The disparity was explained by
the fact that EPA*s funding
priorities were determined
largely by Congress, which
reflected public opinion as to
the severity of environmental
  The board agreed, and asked
itself a question: "What should
be done about a problem posing
high residual risks (as evaluated
by EPA staff or SAB
committees) that the public
perceives as not very serious?
Or vice versa? Such problems
present challenges in risk
communication. It is not clear  if
the 'experts' know things about
these problems that the public
does not and public opinion
about them would change if the
public were better educated.
Alternatively, the public may be
reacting rationally to a
qualitative aspect of the risk
posed by the problem that the
'experts' have failed to take into
account in their analysis."
  The  board gave the answer in
one of its formal
recommendations to EPA; the
recommendation is repeated, in
part, here.
  "In a democracy the support
of individual citizens is
important to the success of any
national endeavor. In the
national effort to reduce
environmental risk, such
understanding and support is
essential, because both the
causes of and solutions to
environmental problems are
often linked to individual and
societal choice. Consequently,
EPA must expand its efforts to
educate the  public in general
and the professional workforce
in particular, both in terms of
what causes environmental risks
and what reduces them.
  "For example, EPA should
work to reduce the gap between
public perceptions of risk and
the scientific understanding of
risk. In many cases, public
perception and scientific
understanding are quite
different, if only because
scientists have ready access to
information that the public does
not. It  is important that EPA
increase its efforts to share  risk
information with the public,
because in the long run the
public will have to approve
EPA's  risk-based action agenda.
Better  public awareness of
relative environmental risks will
help the nation allocate its
resources to maximize risk
  "At the  same time the Agency
must be attuned to the concerns
of people who are closest to the
real-world health, ecological,
and welfare risks posed by
different environmental
problems. An engaged public
often can be helpful in
gathering information that
supports the technical analysis
of risk. Moreover, because they
experience those risks
first-hand, the public  should
have a substantial voice in
establishing risk-reduction
  "Thus EPA should include
broad  public participation in its
efforts to rank environmental
risks. Such participation will
help educate the public about
the technical aspects of
environmental risks, and it will
help educate the government
about the subjective values that
the public attaches to such
risks. The  result should be
broader national  support for
risk-reduction policies that
necessarily must be predicated
on imperfect and evolving
scientific  understanding and
subjective public opinion."
Health Concerns, Not Ecology, Are
Base of Public Risk Assessment

Knowing that EPA's report, Reducing
Risk, was coming out, we felt it
would be useful to discover what
forces lay behind the public's
environmental agenda. We asked
Americans whether the primary
concern behind protecting the
environment was human health or
natural resources. The results are
clear. Worries about personal health
and safety are the prime mover
behind Americans' growing
environmentalism. Far less important
is preserving the environment for the
environment's sake.
  In a Roper survey conducted in
August 1990, more than 6  in 10
Americans said that protecting
human health from pollution is one
of the most important reasons for
protecting the environment. About  4
in 10 believed that protecting natural
resources for future generations is
one of the best reasons, while a third
thought a key objective is to ensure
the existence of natural places and
wildlife. Substantially fewer cited the
need to protect natural resources for
economic or recreational purposes.
  In that same survey, we asked
Americans to weigh a direct trade-off
between human health and ecology:
Which one is the major reason for
protecting the environment? Nearly
three-quarters said it was to protect
people's health;  just a fifth thought it
was to preserve natural places and
  However, the public does not
distinguish between health and
ecological concerns when  it comes  to
individual problems. For instance,
                                                                                                EPA JOURNAL

                                       Other changes in public
                                       opinion, however, suggest
                                       that perspectives are shaped
                                       more by media attention to
                                       problems than by greater
                                       public knowledge of their
  radon in people's homes is as much
  concern to the public for its impact
  on nature and wildlife as it is for its
  effect on human health. Similarly,
  destruction of wetlands is considered
  to be as much a human health
  problem as an ecological one.
    This suggests, perhaps, the need for
  more and better education. However,
  in its defense, it is probably not the
  public's job to determine why
  individual problems need to be
  addressed. Rather, its role is to be
  convinced that  specific problems are
  indeed serious enough to be
  considered environmental priorities.
    The basic standards, then, by
  which expert judgments are made
  have to be popularly understood.
  And that has tremendous
  implications for EPA as it tries to
  broaden the focus of national  policy
  to include ecological risk. For the
  moment, at least, such an effort runs
  against the tide of public opinion.
Implications For the Future

Although popular anxieties about
specific risks have risen in recent
years, the rise suggests not so much a
more sophisticated approach to
establishing priorities, but rather a
broadening of the public's
environmental agenda. More
problems are being added to those
that need to be resolved; relatively
few are being deleted. Americans do
not feel that our environmental
problems are under control, and they
are inclined to look at most of them
as increasingly serious.
  This is good news for our country's
continuing effort to improve the
quality of environment. There is a
definite mandate from the public to
  A change in policy orientation from
human health risks to larger
ecological  risks, however, challenges
the current perspective of most
  Reprinted by permission. Tribune Media Services.

Americans. The underlying rationale
for this change needs to be
communicated convincingly. The
focus, at least initially, should
probably be to explain the value of
natural ecosystems and to draw a
clear connection between them and
human health and welfare. Once this
message has been received, the
public will be in a better position to
understand the types of risks posed
by specific problems.
  Another key issue, especially when
it comes to specific risk assessment,
centers around language—the
language used by scientists,
government officials, and other
experts to communicate to the public,
as well as the language employed by
opinion researchers such as ourselves
to elicit public opinion. Using words
such as "toxic" or "hazardous" to
describe a problem can have a
dramatic impact on the public's
evaluation of the problem.
  Finally, gaps between expert and
public assessments of risks, while
narrower perhaps than in the past,
still exist. In all likelihood  they will
continue to exist. However, in our
opinion, we should not attempt to
bring public perceptions  precisely
into line with those of experts. Such
an attempt would require a massive
educational effort and a lot of time,
time that most Americans, and the
environment, simply do not have.
Instead, the basic objective should be
to cultivate public confidence in the
general goals of our scientific and
environmental leadership, so that
Americans willingly "delegate"
responsibility for specific risk
assessments to those most capable of
making them. Once this is
accomplished, the resources and
funds needed to address our most
pressing environmental problems
should follow,  o

The  Road  to  Innovation
 by F. Henry Habicht
       In September 1990, nearly two years
       into the Bush Administration, EPA's
      Science Advisory Board (SAB)
      released a compelling new report
      entitled Reducing Risk. This
      document made 10 major
      recommendations that, taken
      together, called for fundamental
      changes in the way EPA carried out
      its responsibilities. One
      recommendation has drawn
      particular attention, and generated
      extensive debate, both inside and
      outside the Agency. The SAB
      recommended that EPA's agenda be
      shaped by considerations of relative
      risk. That is, EPA should set
      priorities for future action based on
      the comparative risks posed by
      different environmental problems
      and on the opportunities available for
      reducing those risks.
        The SAB report on Reducing Risk
      was not the first document to
      examine relative  environmental risk.
      In fact, the SAB report was explicitly
      intended to reevaluate and update
      the findings of EPA's landmark
      study, Unfinished Business,
      completed in 1987. But Reducing
      Risk went beyond that; it also
      outlined the main aspects of a risk
      reduction strategy that "takes
      advantage of the best opportunities
      for reducing the most serious
      remaining risks."
        Reducing Risk  thus gave a powerful
      impetus to several initiatives already
      under way at the Agency. Like the
      SAB report, our initiatives are  about
      recognizing and realizing
      opportunities to integrate, to be more
      effective, and to enlist a broader base
      of public supporters in the cause of
      (Habicht is Deputy Administrator of
environmental protection. These
ideas and initiatives have caused
readily apparent changes in EPA's
strategic management and daily
operations. Risk-based planning and
budgeting are not philosophical
concepts that might be applied
usefully in tomorrow's EPA. As far as
EPA's use of comparative risk is
concerned, the future is  now.
The concept of relative risk
reduction also has an
important role  to play when
changes in the  Agency's
legislative authorities are
debated by Congress.
   Since being named EPA
 Administrator in January 1989, Bill
 Reilly has worked to bring new
 flexibility, creativity,  and a
 sharpened focus to the Agency's
 extraordinarily complex legal and
 moral duties. Setting  management
 priorities on the basis of comparative
 risk assessment has been one of the
 most  important ingredients of the
 Reilly philosophy of environmental
 protection. In fact, risk-based
 decisionmaking, Total Quality
 Management, and pollution
 prevention have been three "pillars"
 of EPA strategic thinking since 1989.
   Despite the Administrator's
 commitment to risk-based
 decision making ,and  the SAB's strong
 recommendation, the concept is
 sometimes criticized  as impractical
 and unrealistic. Admittedly, despite
 substantial improvements in recent
 years, environmental data bases
 remain incomplete, and risk
 assessment tools remain imprecise.
 How  then, critics ask, can
comparative risk assessment be a
reliable guide to environmental
  It is important to remember that the
SAB recognized the scientific
uncertainty that underlies—and to
some extent will always
underlie—comparative risk
assessments. SAB members
understood that subjective value
judgments will always play a role in
environmental  policy; they believed
that such a role is  perfectly
appropriate, no matter how
sophisticated the technical and
analytical tools become. Nevertheless,
they strongly supported the increased
use of risk comparisons at EPA. In
the words of the SAB report, "EPA
programs should be shaped and
guided by the principle of relative
risk reduction,  and all available risk
data and the most  advanced risk
assessment and comparison
methodologies  should be
incorporated explicitly into the
Agency's decision-making process."
  The value of  comparative risk
assessment is the pervasive theme
underlying the  first five
recommendations in Reducing Risk.
They are: EPA  should target its
environmental  protection efforts on
the basis of opportunities for the
greatest risk reduction; EPA should
attach as much importance to
reducing ecological risk as it  does to
reducing human health risk;  EPA
should improve the data and
analytical methodologies that support
the assessment, comparison, and
reduction of different environmental
risks; EPA should  reflect risk-based
priorities in its strategic planning
processes; and  EPA should reflect
risk-based priorities in its budget
  In the months since the SAB
released its report, EPA has

                        EPA JOURNAL


            EPA's Science Advisory Board
  recommended initiatives to systematically
       identify and characterize ecological
          problems and trends. EPA's new
 Environmental Monitoring and Assessment
    Program (EMAP) is one such step. This
        near-coastal EMAP survey team is
  measuring dissolved oxygen in the water.

   accelerated some ongoing
   activities—and launched several new
   initiatives—aimed at carrying out the
   central thrust of those five
   recommendations. We are committed
   to a more precise and scientifically
   valid targeting and integrating of the
   Agency's efforts to protect both
   human health and natural
   ecosystems—local, national, and
    The SAB's first
   targeting of EPA resources—is
   inextricably bound up with the use of
   risk-based priorities in EPA's
   strategic planning and budgeting
   processes—the SAB's fourth and fifth
   recommendations. Progress  toward
   the fulfillment of all  three goals
   began in 1989 when Administrator
   Reilly launched a strategic planning
   initiative that focused on risk and the
   potential for reducing it. At that time,
   each EPA office was  called  on to use
   Unfinished Business  and other
   analyses of comparative risks  as the
   basis for setting program priorities.
    This past year, program offices
   have developed four-year strategic
   plans that directly address high-risk
   problems and strive to maximize the
   risk-reduction potential of their
   activities. These strategic plans will
   be updated annually, and new
   information related to risk will play
   an important role in those updates.
    Turning strategic plans into
   effective, real-world programs—and
   then into measurable environmental
   results—is a major challenge faced by
   every EPA employee. To help meet
   that challenge, last February EPA's
   top managers convened in Baltimore
   to begin planning the FY 1993
   budget. At that time the
   Administrator strongly emphasized
   that cross-media, cross-program
initiatives will be an essential part of
EPA's future agenda. As the artificial
walls that have separated EPA
programs in the past begin to
crumble, I believe that the Agency as
a whole will be better prepared to
compare different, cross-program
environmental risks and target
Agency resources accordingly.
  The development of a new
risk-based agenda has particular
impact on EPA's in-house repository
of scientific expertise, the Office of
Research and Development (ORD).
ORD is now readjusting its long-range
research planning process, both to
reflect  priorities dictated by
comparative risk and to refine the
accuracy of risk assessment.
                            EPA photo.

  The Agency's new thinking is not
restricted to headquarters. Two years
ago, EPA Regions 1, 3, and 10
completed comparative risk analyses
based on Unfinished Business. Now
the other seven regions are following
suit.  In addition, a growing number
of state governments are now
benefiting from direct EPA guidance
in this complicated new area of
environmental management.
  EPA is working hard to  ensure that
priorities set in strategic plans are
reflected in  program budgets. In a
number of important ways, risk-based
strategic planning guided the
Agency's FY 1992 budget submission,
completed early this year. A special
EPA  task force of senior managers is

                                         Comparative risk
                                         assessment offers tools that
                                         help us grasp this bigger
     looking for additional ways to
     restructure the budgetary process so
     that it better reflects program and
     regional risk priorities.
       The concept of relative risk
     reduction also has an important role
     to play when changes in the Agency's
     legislative authorities are debated by
     Congress. For instance, relative risk
     information is now being used to
     identify priorities during
     reauthorization of the Clean Water
       The SAB's second
     emphasis on ecological risk—is
     particularly important to
     Administrator Reilly. Before he came
     to EPA,  Reilly was  President of
     World Wildlife Fund and The
     Conservation Foundation. While EPA
     has developed sophisticated methods
     for assessing significant risks to
     human health, we have not
     developed similar tools for ecological
     risk assessment. Thus our ability to
     identify and address the most serious
     ecological risks has been hampered.
       In attempting to steer the Agency
     back to its roots, when attention to
     ecological risks and human health
     risks were better balanced, we have
     launched a major effort to develop
     ecological risk assessment guidelines.
     To provide a firmer foundation for
     implementing those guidelines, EPA
     has funded the National Research
     Council, through its Committee on
     Risk Assessment Methodology, to
     examine the underlying scientific
     issues associated with ecological risk
       Another manifestation of EPA's
renewed emphasis on ecosystem
protection is our new Environmental
Monitoring and Assessment Program
(EMAP). Through this program,
EPA—in cooperation with other
federal agencies—will develop
monitoring data needed to evaluate
the health of the nation's  ecological
resources and measure the
effectiveness of our nation's efforts to
protect them.
  Over the past year EPA has begun
working with the Department of the
Treasury to design
debt-for-environment swaps that
typically reduce a developing
country's international debt while
protecting valuable natural
    EPA's Use of Scientific Data
    —N. Phillip Ross and Suzanne Harris
    Several kinds of sources provide the
    data that go into decision making at
    Ambient Monitoring Programs.
    Measurements of contaminants in
    environmental media are taken at
    regular intervals, usually over long
    periods: for example, measurements
    of ozone in air.
    Laboratory Analyses of Field
    Samples. The analyses assess
    conditions at locations of concern,
    such as abandoned hazardous waste
    Special National or Regional Studies.
    The National Pesticide Survey, for
    example, was undertaken to
    determine  the frequency and
    concentration of pesticide
    contamination in drinking-water
    wells and to better understand the
    causes of contamination.
    Animal Bioassay Studies.
    For example, suspected carcinogens
    are tested by administering controlled
    doses to laboratory animals and
    observing the responses.
     Epidemiological Studies. They
     measure the effects on human health
     from exposure to environmental
     contaminants. An illustration  would
     be a study documenting the effects of
     prolonged exposure of workers to
     materials  containing asbestos.
   Studies of "Biomarkers." They
   measure amounts of environmentally
   transmitted contaminants present in
   the body: for example, lead levels in
   the bloodstream.
   Reports by Industry. The Toxic
   Substances Control Act (TSCA), by
   way of example, and the Emergency
   Planning and Community
   Right-to-Know Act require reports on
   chemical production, usage, and
   Reports by Emergency Response
   Organizations. For example, they
   report releases of environmentally
   harmful substances.
     Data collection at EPA now
   requires over 120 million hours and
   half a billion dollars per year. Some
   data are collected to support
   congressionally mandated
   enforcement programs.  New
   environmental concerns, such as
   global climate  change, drive other
   data collection. EPA's routine
   regulatory responsibilities require
   extensive data on the production,
   use, and  disposal of increasing
   numbers of industrial chemicals and
   on their potential health and
   environmental effects.
     The Agency's decision makers  also
   draw upon data collected by other
   federal agencies, including the
                                                                                                        EPA JOURNAL

                                          . . .  EPA's employees must
                                          be prepared to move
                                          forward in demanding new
     ecosystems. Under President Bush's
     "Enterprise for the Americas"
     initiative, public debt owed to the
     U.S. government by Latin American
     countries will be applied to
     conservation projects in those
       SAB's third recommendation—
     improved data and analytical
National Oceanographic and
Atmospheric Administration and the
Fish and Wildlife Service, as well as
by state agencies and nonprofit
  To make existing data accessible to
a broader audience, many EPA offices
publish inventories that outline the
nature of their data bases  and the
purpose and potential uses of the
data. EPA  and the World Resources
Institute published a  document
earlier this year to improve public
access to environmental statistics.
The Guide to Key Environmental
Statistics in  the U.S.  Government
lists some  80 sources of statistics.
EPA is updating and  expanding the
guide to include sources from public
and private sectors.
  EPA plans to establish a national
center for  environmental statistics
that will provide services comparable
to those of other federal programs,
such as those at the Bureau of Justice
Statistics,  the Bureau of Labor
Statistics,  and the National Center for
Health Statistics. Its primary function
will be to  publish regular reports on
the quality of the environment. It will
also develop new methodologies to
integrate data from different sources
into a more complete picture of
environmental change.
  As long  as EPA must rely not only
on statistical analysis of data but on
models, which contain assumptions
that cannot be proven by existing
     methodologies—is discussed
     in the accompanying box by N.
     Phillip Ross and Suzanne Harris.
     The EMAP program also advances
     this goal through its collection and
     integration of ecological data.
       In addition, EPA's Risk Assessment
     Council is updating and improving
     its human health risk assessment
data, some controversy over its
decisions will he inevitable. For
example, the highly complex models
of global warming must employ many
assumptions, because scientists do
not have complete data on changes in
the Earth's temperature and the
factors contributing to such changes.
Further, scientists do not know
exactly how the process of
carcinogenesis works in humans. We
assume that  the effects  in animais
receiving high doses of a chemical
can be related to the long-term effects
of low doses in humans. In both
examples, varying the assumptions  of
the model can change the outcomes.
  Decision makers ultimately must
rely on judgment: Does the weight of
the scientific evidence justify a
regulatory decision or not? Where
risks are grave, it may be ill advised
to defer decision until complete
information  is available. EPA has
been in the forefront in developing
guidelines for interpreting
toxicity-study results. These
guidelines provide a framework for
decision making in the  face of
scientific uncertainties.
(Dr. floss is Chief of the Statistical
Policy Branch in EPA's Of/ice of
Policy, Planning, and Evaluation.
Harris is  affiliated with Stretton
Associates, Inc.]
guidelines to reflect current science.
New guidelines on developmental
toxicity, exposure assessment, and
non-cancer effects will be completed
this year. We also are updating our
cancer risk-assessment guidelines.
The National Academy of Sciences is
providing technical advice in these
  Needless to say, the development
of sound, comprehensible
environmental indicators which cut
across media programs is enormously
important. We must develop a
common scientific currency and
nomenclature which we can use
consistently in all the key phases of
EPA management: planning,
budgeting, annual operations, and
measuring progress for
accountability. This is a foundation
which we are committed to build.
  To implement the initiatives
described above, EPA's employees
must be prepared to move forward in
demanding new  directions. Thus
training programs must be improved
to incorporate the tools and
techniques of comparative risk
assessment. Training is the work of
the EPA Institute, which now is
providing advanced courses in
comparative risk assessment  and risk
management both to Agency
employees and to experts from  state
government. We  are also working
with the SAB to  improve our analysis
of the true economic effects of
pollution and controls to ensure the
soundest possible strategies.
  Much of the motivation for these
changes is coming from our new
philosophy of Total Quality
Management (TQM), which
encourages ideas for improvement to
be developed by  all EPA employees.
In a very real sense, TQM is to
risk-based management what the SAB
report is to environmental protection
as a whole—an integral, empowering

Improved risk communication and dialogue on comparative risks and priorities
can help EPA build a better base of public support. Understanding the causes
and consequences of an environmental problem can be the first step toward its
component of our overall approach.
  TQM will be the engine of EPA's
progress into the future because it
will help our employees rise above
the program-specific and
medium-specific concerns that have
characterized EPA's work in the past.
Institutional rigidity is an obstacle to
innovation. To break down these
barriers, cross-media thinking and
interaction are being encouraged at
every opportunity, and the Agency is
embracing this approach not only in
its own work but also in its dealings
with other federal  agencies and state
and local governments.
  Finally, the SAB report is far more
than a technical  management
document of interest only  within
EPA. In fact, the spirit of the report's
other recommendations is daringly
outward-reaching and
forward-looking. In essence, the SAB
has defined our nation's long-range
environmental challenge: involving
all the different parts of our
society—citizens, business, and all
levels of government—and using all
the tools at our disposal—regulatory
and non-regulatory—to reduce
environmental risk.
  To meet this challenge, EPA has a
responsibility to inform and motivate
people so that they practice
environmental stewardship in their
daily lives. And, as part of a TQM
approach to our work, we must also
listen closely to experts and affected
persons early in our decision making
process. This responsibility to
communicate is a new dimension to
our work, and a daunting one. The
vast majority of America's 250
million citizens are not likely to take
the time to understand comparative
risk assessment. So  EPA is taking
several steps to help the public gain a
better understanding of the risks they
face and what they can do to reduce
  Rather than publicizing  arcane
statistics about parts per million of
suspended solids, we are using the
new techniques of risk
communication to raise public
awareness of different kinds of
environmental risks and win support
for national activities —public and
private—that reduce those risks. We
are trying to focus public attention on
specific natural resources or
geographically identifiable
systems—like the Great Lakes or the
Grand Canyon—because, as Jacques
Gousteau once said, "People protect
only what they love."
  Through the recently created  EPA
Office of Environmental Education,
we are also taking  steps to educate
the voters of the future. Students
already are benefiting from grants
authorized by Congress in the 1990
statute creating the office. Recycling
is a key theme of environmental
courses now being offered in our
  In  all these ways, EPA is moving
forward with confidence into the
brave new world of risk-based
environmental protection, Even
though existing environmental data
are incomplete, and existing
technical and analytical tools are
flawed, comparative risk assessment
can help us put all the different kinds
of  environmental problems we face
into an integrated perspective. The
job we do here at EPA is bigger than
the sum of its parts, and EPA is
bigger than the sum of all the
program offices into which it is
divided. Comparative risk assessment
offers tools that help us grasp this
bigger picture. These tools can open
up vast new opportunities for EPA in
improving environmental protection
and build a deeper base of public
support. I am proud of the hard work
already underway to realize these
opportunities, a
                                                                                                     EPA JOURNAL

   A  Dissenting Voice
   by Senator David Durenberger
   Some cautions I will raise
   are also stated in the SAB
   report, but they have been
   swept aside in the
   enthusiasm with  which the
   report has been  embraced.
(Durenberger (R-Minnesota)
serves on the Senate Committee on
Environment and Public Works.]
"T"he report of the Science Advisory
 I Board, Reducing Risk: Setting
Priorities and Strategies for
Environmental Protection, makes an
important contribution to the
national debate on environmental
  The board's endorsement of
pollution prevention and market
incentives as public policy tools is
appreciated. The Congress has made
a start in these areas with the acid
rain provisions of the Clean Air Act
Amendments and the Pollution
Prevention Act, both passed in the
waning days of last year. We can do
more in these areas, and the report
provides many useful examples
which deserve to make their  way into
EPA programs.
  But I cannot wholeheartedly
endorse the fundamental theme  in
Reducing Risk. That  theme is woven
from three propositions.
  First, health and environmental
threats may be measured along a
unidimensional yardstick. To quote
from the report,
  The concept of environmental
  risk, together with its related
  terminology and analytical
  methodologies, helps people
  discuss disparate environmental
  problems with a common
  The second proposition is  that an
expert assessment  of environmental
risk can help prioritize society's
investment in environmental
  There are heavy costs involved
  if society fails to set
  environmental priorities based
  on risk. If finite resources are
  expended on lower-priority
  problems at the expense of
  higher-priority risks, then
  society will face needlessly high
  risks. If priorities are
  established based on the
  greatest opportunities to reduce
  risk, total risk will be reduced
  in the most efficient way ....
  And the third proposition is that
 public opinion, reflected in the
 environmental laws enacted by
 Congress, is not a reliable guide when
 it comes  to setting priorities:
  Because most of EPA's program
  offices  have been responsible
  for implementing specific laws,
  they have tended to view
  environmental  programs
  separately ... and questions of
  relative seriousness or urgency
  have remained unasked.
  Consequently, at EPA there has
  been little correlation between
  the relative resources dedicated
  to different environmental
  problems and the relative risks
  posed by those problems ....
  There are many flaws in these
arguments. Some cautions I will raise
are also stated in  the SAB report, but
they have been swept aside in the
enthusiasm with which the report
has been  embraced. The
counter-intuitive notion, first stated
in Unfinished Business, that we may
be spending scarce resources on the
wrong problems is intoxicating for
some, so much so that the practical
realities of science and politics are no
longer recognized as important
  My first set of cautions might be
described as methodological. These
are problems, theoretical and
practical, with comparative risk
assessment. The most obvious are the
gaps of information. We don't know
enough to make comparisons among
risks. Our models for cancer risk
assessment are in their infancy. We
know much less about the
mechanisms for other effects, like
birth defects and neurotoxicity. Data

                                    How does one compare a
                                    case of lung cancer in a
                                    retired petrochemical
                                    worker to the loss of
                                    cognitive function
                                    experienced by an urban
                                    child with lead poisoning?
on human exposure to these hazards
are limited.
  The methodological problems go
deeper. There is no objective
yardstick along which risks can
reasonably be compared. How does
one compare a case of lung cancer in
a retired petrochemical worker to the
loss of cognitive function
experienced by an urban child with
lead poisoning? How  do we make
choices between habitat and health?
  Suppose that EPA had two
programs, one to prevent cancer
caused by radon, and the other to
protect wetlands for the use of
migratory waterfowl. How much
should the Agency spend on each?
Which presents the greater
"environmental risk"?
  The SAB report  proposes that we
spend as much protecting the
ecosystem as we do protecting public
health. In the long run, according to
SAB, human health depends on the
health of the environment. But equal
funding  is a stab in the dark, no more
expert a guess on the relative value of
these two "environmental risks" than
you could get from your spouse, your
neighbor, or your congressman.
  The proper balance in the EPA
budget between habitat and health
cannot be found in comparative risk
assessment. It's a question that can
only be answered by an appeal to
public opinion. We must do our best
to inform public opinion about the
consequences of various choices.
Public health and  environmental
science is critical in that role.  But in
a democratic society,  it is a mistake
in method to think these questions
can be answered without asking the
public about its priorities.
  The problem of ground-water
pollution illustrates the point.
Comparative risk studies suggest we
assign low priority to ground-water
protection programs like Superfund.
Agency professionals compare
ground water to other human health
problems and rank it low. There is
little evidence of health-threatening
contaminants in the ground water
used for drinking water supplies.
  Why, then, is so much money
spent on Superfund? It may be that
the public measures ground water
differently than do the experts. The
public may see it as a natural
resource, like waterfowl habitat, that
is valued for reasons other than its
current public health impact. This is
a methodological flaw. One cannot
substitute quasi-scientific
comparisons along a single
dimension, like cancer risk, for
judgments made by the public that
reflect a bundle of different values.
  My second caution is about equity.
That's what it is called in the SAB
report. The public has more on its
mind than body counts. Its
evaluation of risk is not like the
simple calculus of the health service
professional. The public will accept
relatively small risks spread evenly to
many, especially if they are voluntary
risks, more readily than it will accept
large, involuntary risks imposed on
the few. Superfund is, in part, about
fairness; it is not just about public
  Equity value extends to future
generations. It is intergenerational.
Again, ground water is a case in
point. The average glass of ground
water poured in the United States fell
as rain water 200 years ago. It has
taken generations to percolate to the
                                           St. Joseph Gazelle. December 14. 1983.
                                                             EPA JOURNAL

                                                                Superfund, the author argues, is
                                                                about fairness as well as public
                                                                health, an issue brought home
                                                                when involuntary risks affect
                                                                people's families and residences.
                                                                In 1978, kids joined adults in
                                                                demanding relocation from Love
                                                                Canal—a Superfund site which
                                                                became famous for its chemical
                      SIT  AT
                                                   Wide World photo.
    well. As a guide to environmental
    priorities,  mortality and morbidity
    from ground-water pollution is not
    much of a factor today. It will be
    generations before today's pollution
    shows up in the glass of drinking
      Most Americans don't embrace the
    environmental ethic out of a concern
    for public health statistics. The
    public's fundamental concern is,
    perhaps, best expressed in the
    bumper sticker, "Save the Planet."
   Their highest value is
   intergenerational, passing on a world
   at least  as good as  the one they
   received. They don't believe that the
   future can  be carefully engineered.
   They know that science isn't that
   good. So they choose their own
   inheritance as a guidepost and hope
   to leave as much as they found.
   Ground-water contamination is a
   violation of that value system,
   whatever its current public health
   impacts. The comparative risk
reports, both Unfinished Business
and Reducing Risk, have been blind
to the environmental ethic which
motivates most Americans.
  My final caution is strategic. There
is an explicit assumption in these
reports that the resources we can
devote to environmental problems are
limited. It is a  matter of priorities, of
properly dividing the pie.
  I don't buy that assumption. It
doesn't reflect  the way  we make
resource-allocation decisions in our
government. Seen over  the long run,
the resource-allocation  process is not
a zero-sum game. Superfund doesn't
compete with indoor air pollution,  or
worker health and  safety, or mallard
  When Superfund was enacted,
Congress did not close  down
existing environmental  programs  to
provide the financing. The program
was paid for with a new tax on
chemicals.  Comparing Superfund
(judged by  the  experts to present  low
 risks) with ozone depletion (judged
 to present high risks) will not
 produce any additional dollars to
 keep chlorine out of the stratosphere.
  In the short term, and at the
 margin, there are some tradeoffs
 among EPA programs in preparing an
 annual budget.  But seen from a
 longer perspective, spending on the
 environment is only a small part of
 the very large federal budget.  Our
 commitment to the environmental
 portion  of the budget has grown
 consistently as  new risks have been
 recognized and addressed.
  This point extends to the regulatory
 side, as  well. Some question the large
 costs that are being imposed on the
 private sector in cleaning up
 hazardous wastes and leaking
 underground storage tanks. Are those
 the most serious risks, they ask. Well,
 if we repealed  RCRA, would there
 suddenly be more money to abate
 indoor air pollution or control
 runoff from farm fields and city
 streets? And how can a comparative
 reference to the risks of indoor air
 and nonpoint pollution be used to
 justify unabated contamination of our
 ground-water resources by waste
 dumps and leaking tanks?
  So,  those are  my cautions. Our
 methods aren't suited to making
 these comparisons. The public holds
 and expresses values not reflected in
the comparative risk  calculus. We
 must not cripple our vision of what's
 possible by insisting  that new
 problems only be solved by
abandoning some part of our current
commitment to  protecting public
health and  the environment. The
 insights produced by risk assessment
can make a valuable contribution to
the public debate on  environmental
priorities. But it is no substitute for
careful attention to the public's
values. D

800-Pound  Gorilla
                                                             Texas Plastics Maker Assessed $3.4 Million
                                                             For RCRA Violations
  Former Administrator Bill
  Ruckelshaus once referred to
  the Agency's enforcement
  function as EPA's 800-pound
  gorilla in the closet, a strong
  deterrent to those who would
  violate the environmental
  laws protecting the nation's
  air, water, and land
    Today, at headquarters and
  regional offices the Agency's
  enforcement staff numbers
  more than 4,250. As
  Administrator Reilly pointed
  out in his article in this issue
  of the Journal, over the past
  two years this gorilla has
  been setting records in
  virtually every category.

  •  Polluters in Fiscal Year
  1990 paid the highest amount
  in penalty dollars in EPA
  history, with $61.3 million in
  civil penalties. This
  represents a 74 percent
  increase over FY 1989.

  •  During Reilly's tenure  (FY
  1989-1991), EPA has obtained
  more than $96 million in
  civil penalties from some
  3,115 cases. This represents
  almost 40 percent of all civil
  penalty dollars obtained
  throughout the Agency's

  •  EPA referred a record 375
  civil cases to the Justice
  Department in FY 1990, and
  a record 65 criminal cases.

  •  Eight programs established
  new records for high
  individual penalties within
  their programs in either
  administrative or judicial
(iemiri Murtineau pfmlo. The Washington Post.
 • More than half the
 individuals convicted for
 environmental crimes in FY
 1990 were given prison
 sentences; about 85 percent
 of those serve their time.
 Prison time is averaging in
 excess of one year.
   The following reports
 provide a sampling of what
 EPA and the Justice
 Department are doing to
 discourage violators.
Formosa Plastics Corporation
of Point Comfort, Texas, will
pay a $3,375,000 penalty, the
largest ever collected by EPA,
for violations of the Resource
Conservation and Recovery
Act, the nation's hazardous
waste and solid waste law.
  In addition to the civil
penalty, payable within 21
days to the U.S. Treasury,
Formosa officials also agreed
to set up a $1 million trust
fund for environmental
education in the surrounding
area, including donation of
property for nature
sanctuaries and other
ecological uses. The  legal
settlement also calls  for the
company to clean up 6
million gallons of process
waste in holding ponds and
pump and treat up to 4
million gallons a year of local
ground water for as long as
20 years.
  The company makes
polyvinyl chloride (PVC)
powder. A production
byproduct, ethylene
dichloride or EDC, was found
to be contaminating ground
water under the company's
holding ponds. EDC  is highly
toxic and a known
carcinogen. In an
administrative legal action,
EPA charged Formosa with
improperly handling and
disposing of hazardous and
solid waste and operating a
hazardous waste facility
without a permit, among
other complaints.
  The Texas Water
Commission, an
environmental agency for the
state, documented the
chemical contamination at
the plant and played a major
role in EPA's legal action
against the plastics company.
  The land  disposal
restrictions of RCRA require
treatment of most hazardous
waste, allowing only
                                                           adequately treated waste and
                                                           residue from treatment to be
                                                           disposed on land. The
                                                           restrictions apply to all
                                                           persons  who generate or
                                                           transport hazardous waste or
                                                           who own or operate facilities
                                                           that treat, store, or dispose of
                                                           waste. Agency officials stress
                                                           that RCRA, and its
                                                           enforcement, actively
                                                           encourages advanced
                                                           treatment, recycling, waste
                                                           minimization, and alternative
                                                           hazardous waste control
                                                           technologies in lieu  of land
                                                                                        28 More RCRA Actions
                                                                                        By Justice and EPA

                                                                                        In what has been called a
                                                                                        nationwide crackdown to
                                                                                        enforce the Resource
                                                                                        Conservation and Recovery
                                                                                        Act ban on land disposal of
                                                                                        hazardous waste, the Justice
                                                                                        Department has filed eight
                                                                                        judicial actions in federal
                                                                                        courts, and EPA has taken
                                                                                        administrative enforcement
                                                                                        actions against 20 facilities,
                                                                                        assessing over $3.5 million in
                                                                                          The combined actions
                                                                                        include a penalty of $1.85
                                                                                        million against Du Pont in a
                                                                                        judicial settlement involving
                                                                                        its Chambers Works facility
                                                                                        in New Jersey. As part of the
                                                                                        settlement, Du Pont agreed to
                                                                                        perform pollution prevention
                                                                                        activities to identify and
                                                                                        assess opportunities for
                                                                                        reducing the generation of
                                                                                        hazardous waste.
                                                                                          EPA's administrative
                                                                                        enforcement actions include a
                                                                                        facility owned by Ciba-Geigy
                                                                                        Corporation in Mclntosh,
                                                                                        Ala.; a facility of B.F.
                                                                                        Goodrich in Spencer, W.Va.;
                                                                                        and a Boeing Company
                                                                                        facility in Everett, Wash.
                                                                                                           EPA JOURNAL

Know Violations Cost
Two Companies $98,000

Two New Jersey firms agreed
to pay $98,600 in fines for
failing to file toxic release
inventory forms for 1987 and
to meet reporting
requirements in the future.
  The Emergency Planning
and Community
Right-to-Know Act requires
facilities with 10 or more
employees that manufacture,
process, or use more than
"threshold" amounts of
certain chemicals to report
chemical emissions to EPA
and state agencies.
  The two New Jersey
companies involved, Alford
Packaging in Ridgefield Park
and Hoeganaes Corporation
in Riverton,  signed consent
decrees to pay $12,750 and
$85,000 respectively for their
Texas Company Cited
For TSCA Violations
EPA has issued an
administrative civil
complaint against Champion
Technologies, Inc., (formerly
Champion Chemicals) of
Houston, Texas, citing the
company for violations of the
Toxic Substances Control Act
(TSCA). That law says no
person may manufacture,
import, process, or otherwise
use a chemical substance not
listed in EPA's Chemical
Substance Inventory.
Champion is charged with
manufacture and commercial
use of an unlisted chemical
and with failure to abide by
inventory rules at two of its
facilities. EPA is asking  a
$162,000 penalty from the
Hoboken Fined $225,000
For Waste

The city of Hoboken, N.J., has
agreed to pay a penalty of
$225,000 for discharging
polluted waste water into the
Hudson River in violation of
the city's discharge permit
and the Clean Water Act.
Under an agreement with
EPA, the  city will upgrade its
sewage system to provide
secondary treatment by 1993
and, meanwhile, take steps to
improve operations at
existing facilities. Sixty
percent of the penalty goes to
the federal government and
40 percent to the tri-state
environmental agency that
joined EPA as a plaintiff in
the case.
USX Charged With
Clean Air Act

EPA has filed a civil suit
against USX Corporation
(formerly U.S. Steel) for
violations of the Clean Air
Act at the company's
Clairton, Pa., plant, charging
USX with using contaminated
water to cool coke and with
releasing raw coke-oven gas.
The Agency seeks an
injunction requiring USX to
install pollution control
equipment and otherwise
bring the facility into
compliance with state and
federal clean air rules. The
suit also seeks penalties of up
to $25,000 per day per
violation, plus litigation
Rate  of Ozone Depletion
Double  Earlier Estimate
New data from NASA suggest
the protective ozone layer
over the United States has
been depleted by four to five
percent since 1978,
approximately double earlier
estimates. As a result of this
higher level of depletion,
EPA estimates there could be
200,000 more deaths from
skin cancer in the United
States over the next 50 years.
  The ozone layer limits
penetration of high-energy
ultraviolet radiation to the
Earth's surface. Exposure to
the radiation may cause skin
cancer and damage plants
and aquatic life.
  Responding to the new
NASA data, EPA
Administrator Reilly said he
was intensifying Agency
efforts to reduce the use of
ozone-depleting chemicals,
among them CFCs, widely
used in air conditioning and
refrigeration. Other ozone
depleters include halons, a
fire suppressant; carbon
tetrachloride, a commonly
used solvent; and methyl
chloroform, another widely
used commercial solvent.
  Worldwide efforts to limit
the use of ozone-depleting
substances have progressed
rapidly over  the past several
years. A landmark
international treaty, the
Montreal Protocol, has now
been signed by almost 70
nations and was significantly
strengthened at a meeting last
June. The amended Protocol
calls for a phase-out of CFCs,
halons, and carbon
tetrachloride by 2000 and
methyl chloroform by 2005. It
also establishes a fund to
assist developing countries in
meeting their obligation to
limit use of ozone depleting
  "The United
States—government and
industry—has long played a
leadership role in efforts to
protect the ozone layer,"
Administrator Reilly said.
"The new information from
NASA suggests we may  need
to do still more. We are
exploring the full range of
options, including
intensifying efforts to assist
developing countries and
accelerating efforts to bring
ozone-safe substitutes on
New Report
Shows Progress
in Air Quality
EPA's 17th annual report on
urban air quality, released
March 5, 1991, shows
progress for six major
pollutants over the period
from 1980 through 1989.
  The report, "National Air
Quality and Emissions
Trends, 1989" is based on
data from some 4,000 air
pollution monitoring stations
nationwide and deals with
the pollutants for which EPA
issues national standards.
During the  10-year period
1980-1989, the report shows
the following changes in
average ambient amounts of
the pollutants:

• Smog levels decreased 14

• Lead in the atmosphere
decreased 87  percent.

• Sulfur dioxide fell 24

• Carbon monoxide
decreased 25  percent.

• Particulates (dirt, dust,
soot) decreased 1  percent in
the years 1982-1989.
• Nitrogen  dioxide decreased
5 percent.
  "The report shows
substantial  progress in
reducing atmospheric levels
of our most pervasive
pollutants during a period of
considerable economic
growth," said EPA
Administrator Reilly. "This
means our country's

significant investments in air
quality are paying off.
  "The report also shows the
magnitude of the problem
still remaining: Over 84
million Americans are
breathing air that violates at
least one federal standard; 67
million are living in counties
exceeding the smog  standard;
while almost 34 million are
in counties exceeding the
carbon monoxide standard;
and over 27  million  live in
areas violating the particulate
  Reilly went on to say the
Clean Air Act Amendments
of 1990 incorporate proposals
by President Bush to bring
most American cities into
compliance with the smog,
carbon monoxide, and
particulate standards by the
year 2000, without hindering
economic growth. [The Act,
as well as EPA control
measures  in  other fields, will
also reduce sulfur dioxide,
lead, and  nitrogen dioxide.]
  For copies of the report
(118 pages) or additional
information, contact:
Dr. Thomas C. Curran
Technical Support Staff
Office of  Air Quality
Planning and Standards
Research Triangle Park,
North Carolina 27711
Phone: (919) 541-5558
Agency Sets  New  Standards
for Lead in Drinking Water
As part of a continuing
nationwide program to
reduce human exposure to
lead in the environment, EPA
has set tighter new standards
to lower greatly the level of
lead in drinking water.
  In a press conference held
in Washington May 7, 1991,
Deputy Administrator F.
Henry Habicht said the new
rule will give the United
States the  most stringent
drinking water standards for
lead in the world: "EPA is
putting in place a program
that will significantly reduce
lead exposures to  130 million
Americans within a period of
six  years and will bring the
blood lead levels of an
additional 560,000 children
below 10 micrograms per
deciliter of blood, which is
the level of concern—the
safety line."
  Over a period of 10 years,
the  phase-down of lead in
gasoline removed 90 percent
of lead from the air and
reduced children's blood lead
levels about  70 percent.
According to public health
findings, drinking water
accounts for 10 to 20 percent
of children's total exposure to
lead. Lead-based paint and
urban soil and dust are other
sources. The present average
blood lead level is
approximately 6 micrograms
per deciliter of blood.
However, there are significant
pockets of population where
levels are  higher.
  One element of the new
drinking water strategy
requires 79,000 public water
suppliers to  monitor for lead
at household taps. Large
water systems, those serving
more than 50,000 people, are
required to begin monitoring
by Jan. 1,  1992. Medium-size
and small  systems start later.
  Another element of the
plan focuses on reducing
corrosion of lead from pipes,
solder, and fixtures between
the water treatment plant and
the consumer's tap. The more
corrosive the water leaving
the treatment plant, the
greater the chance of leaching
lead from plumbing and
carrying the lead to the
  Under the EPA plan, all
800 large water systems,
those serving 60 percent of
the nation's population, will
have to begin optimizing
their corrosion control by
1993. Many large systems are
already doing so, in
anticipation of the new
  "I want to emphasize that
95 percent of the benefits of
this rule will be achieved
within six years, and  many of
the benefits will begin to be
realized within two years. For
example, corrosion control
will begin in earnest in two
years in many cities,"
Habicht said.
  The goal of the new
standards is to reduce lead
levels to 15 parts per  billion
(ppb) or less at the "first
draw" in the morning  for at
least 90 percent of monitored
household drinking water
taps. Tap water is likely to
have its highest lead content
of the day after standing
overnight in household
plumbing. Prior to the new
standards, allowable lead
levels were 50  ppb, measured
anywhere in the water
distribution system.
  Hundreds of thousands of
homes across the country will
be monitored to determine
lead levels. The findings in
each community will
Steve Defcmey photo.

determine the actions a local
water supplier will be
required to take to achieve
the 15 ppb target within the
time specified.
  After monitoring begins,
water supply systems that
exceed the new action level
for lead will be required to
install or improve corrosion
control and must inform
customers how  to minimize
exposure to drinking-water
lead through an
EPA-developed public
education program.
  More information about
reducing  exposure to lead is
in a free booklet entitled Lead
and Your Drinking Water,
available from  EPA's Public
Information Center; 401 M
Street, SW; Washington, DC
20460; (202) 475-7751.
                                                                                                            EPA JOURNAL

EPA Introduces New Awards  Program
In recent ceremonies held in
Washington, DC, EPA
honored 10 national winners
of the Agency's new awards
program for environmental
achievements, the
Administrator's Awards
  Winners in this, the first
year of the program, were
honored for innovations in
municipal waste recycling. A
special award was made for
achievements in
environmental education.
  Awards categories and the
winners are:
  Citizen: Bob Kerlinger,
Poquoson Recycling Center,
Poquoson, Virginia, for
founding and coordinating a
volunteer recycling center,
Mike frisson photo.
the success of which has
exceeded expectations and is
turning a profit for
participating civic groups.

  Community, Civic, and
Non-Profit: Seattle Tilth's
Community Composting
Education Program,  Seattle,
Washington, for extensive
community training and
education in composting that
is diverting 5,300 tons of  yard
waste from the local waste

  Educational Institutions
(Kindergarten-12fh Grade):
Aurora Public School,
Aurora, Colorado, for
developing a teacher's guide.
The curriculum educates  and
helps students make
responsible decisions
affecting solid waste

  Colleges and Universities:
University of Wisconsin,
Stevens Point, Wisconsin, for
a comprehensive recycling
program that involves the
student body, faculty, and
university management. It
includes the use of pellets
from the paper industry to
fire a coal boiler, displacing
313 tons of coal, reducing
emissions of sulfur dioxide,
and saving nearly $3,500.

  Large Business: Fort
Howard Corporation, Green
Bay, Wisconsin, for
establishing a "recycling
advocacy program" which is
evident in all facets of the
paper manufacturer's
operation. It involves
recycling relationships within
the corporation, with
businesses, local
communities, civic groups,
and others.

  Small Business: eegee's
Inc., Tucson, Arizona, for
introducing a recycling
program for polystyrene foam
food containers  and other
wastes, and for getting other
Tucson businesses involved
in the recycling program.
Proceeds from the sale of
recyclables go to local

  Local Government: City of
Newark, New Jersey,  for
maintaining one of the
                                                          Nicole Miceli, a
                                                          University of
                                                          Point employee, loads
                                                          a compactor that can
                                                          bail as well as
                                                          compact cardboard. In
                                                          EPA's first
                                                          Awards Program, the
                                                          university's recycling
                                                          project won first place
                                                          in its category.
highest recycling rates in the
nation, including an
innovative program for
recycling ozone-depleting
compounds, and has
instituted purchasing of
recycled and recyclable
goods. The city also
deputizes youth as
"Recycling Ranger" to involve
young people in recycling.

  State Agencies: State of
Rhode Island, for
implementing the nation's
first comprehensive and
mandatory recycling law {in
1986). Fourteen percent  of
residential waste is now
recycled. Commercial waste
at landfills has decreased 24
percent since 1989.

  Federal Agencies: U.S.
Navy, Naval Submarine  Base,
Bangor, Silverdale,
Washington, for introducing a
base-wide collection and
recycling program that has
spread to local communities
and been adopted by other
military facilities.
  Environmental Education:
HDR Engineering, Inc., White
Plains, New  York, for
sponsoring, together with the
TV show "Mr.  Rogers'
Neighborhood," the first
major recycling and
conservation education
program aimed  at
preschoolers. Audience for
the  program  is estimated at
40 million.

  In saluting the winners,
Administrator Reilly said
their projects are "national
role models" that can be
replicated in other
communities. "We  were
delighted with the
tremendous response to our
first awards program and
with the high quality of the
  Awards for 1991  will be
made  for achievements in
pollution prevention. For
more information, contact
any regional  office  of EPA (in
late summer).


How  Does
Your  Garden  Grow?
A Book Review by Douglass Lea
      Although his day job, helping to
      edit Harper's Magazine,
   sparkles with sophistication,
   Michael Pollan is still folksy
   enough to see  the humble
   American gardener as a true heir of
   the mythological Sisyphus, the
   ancient king condemned in Hades
   to an eternal struggle against the
   forces of nature.  The unpretentious
   editor grounds his epic  vision of
   the gardener's  fate in personal
   experience: He are one.
     He is also a  compelling writer.
   Urbane scholarship, practical
   advice, and perceptive description
   are combined  irresistibly in his
   new book Second Nature, the
   sadder-but-wiser story of Pollan's
   coming to terms  with the
   intractable demands of  "his" plot of
   (Lea, a writer and editor, grows mostly
   metaphors in his garden in Waterford,
   Virginia. He a/so teaches government and
   politics in The American University's
   Washington  Semester Program. He will be
   a contributing editor of EPA Journal,
   producing this feature.}
  In the final analysis, Pollan
learns, the garden only partly
belongs to him. Other creatures,
both animal and vegetable, also
have strong claims to his domain.
And they have been waiting
patiently for someone just like
him—someone overly clever and
absurdly energetic—to appear and
bring forth a newly disturbed patch
of ground.
  His garden, Pollan  inevitably
discovers, harbors a powerful array
of biological and geophysical
imperatives that insist on
manifesting their own destiny.
They resist the geometric overlays
of human design. Their chaotic
patterns and turbulent cycles defy
the logic of human control. The
garden seems to possess a mind of
its own.
  At almost every turn, Pollan
meets  existential dilemmas and
ponders epistemological questions.
This intellectual nomad tethers
himself loosely to his gardens and
then roams widely: from the humor
that pervades early memories of
family gardens to the subversion of
Emerson's sophistry on the glory of
weeds and Thoreau's banality on
the romance of nature; from a long,
discursive essay  on the lawn,
which has served "to unify the
American landscape," to the details
of planting a tree; and from the
moral drama of compost, "our
outward sign of horticultural
grace," to an argument for caution
in intervening into the immense
complexity of natural processes.
These and other  matters are
organized in chapters that follow
the seasonal march of the calendar.
  Second Nature artfully dodges
the snares that typically plague
books on gardening and nature.
Loaded with how-to information, it
nevertheless avoids becoming an
arid recitation of familiar facts and
data. Committed to a high standard
of environmental citizenship, it
avoids preaching a message of
Manichaean divisiveness. And,
written by a real writer, it avoids
rhapsodizing about nature.
                                                        EPA JOURNAL

    As a current example of
  "environmental" writing, Second
  Nature performs a useful
  pedagogical function: It rescues the
  language of the genre from the
  rather perfunctory and dispirited
  state into which  it has fallen.
  Protecting the environment has
  become a rather abstract enterprise.
  And its language has begun to
  reflect great distance from ordinary
  human experience: parts per
  billion; CFCs; no net loss; SDWA;
  mutagens; VOCs. And on and on
  through  reams of testimony,
  hundreds of dockets, vast libraries
  of technical reports.
    It is the language of
  professionalism, of lawyers,
  scientists, and policy makers.
  Almost immediately after the
  rhetorical flights of Earth Day,
  professional jargon began to
  infiltrate the public  discourse of
  conservation and environmental
  protection. While convenient for
  efficient communication of esoteric
  information, the new language
  leaves the average citizen unmoved,
  uninformed, unexcited.
    To his everlasting credit, Pollan
  uses the deceptively simple device
  of a garden book to re-invigorate
  conversations about our
  environment, about our  places and
  our surroundings. "Much of
  gardening is a return," he writes,
  "an effort at recovering remembered
  landscapes." Pollan's audacity is
  subtle. With thick description and
  layered nuance, he ties
  down-to-earth gardening to larger,
  more global concerns. In the end,
he succeeds magnificently, and his
book is likely to be passed from
hand to hand for generations to
  From a variety of angles and
perspectives, Pollan is essentially
saying that to make a  garden is to
manage in the middle. A garden
manifests the dry principles of
compromise. It mediates between
nature and culture. Every garden
has its own special conditions, its
own unique combination of vectors.
Climate, weather, soil, water, light,
and ecological factors influence its
design and set its parameters. Since
figuring all this out is more art than
science, Pollan learns to "design
with nature," the title of Ian
McHarg's seminal treatise on
harmonizing human occupation
with natural processes.
  Public opinion polls now say that
gardening is America's most
popular leisure activity. Some do it
for creativity and a sense of
craftsmanship; some,  for
self-sufficiency, independence, and
health; some, for relief from
modern stress and pressure; and
others, of course, for the sheer
beauty of the enterprise and its
results. Whatever the ostensible
motivation, virtually all modern
gardeners share a powerful urge to
forge a new partnership with
nature—that is, to accept the local
givens and limits of nature, to
preserve it as much as possible, to
restore it wherever possible, to
enhance it, work with it, honor it.
  These same sensibilities are also
broadly at work in the
environmental movement of the
past two decades, particularly in its
emphasis on ecological
interrelationships. Second Nature,
published by the Atlantic Monthly
Press, is Michael Pollan's
demonstration of  how the worlds of
the garden and the
environmentalist are inextricably
linked. Gardening is a large portal
into environmentalism.  n

        A Lesson  from  The
        Immense Journey
A    little while ago—about one
   hundred million years, as the
geologist estimates time in the
history of our four-billion-year-old
planet—flowers were not to be
found anywhere on the five
continents. Wherever one might
have looked, from the poles to the
equator, one would have seen only
the cold dark  monotonous green of
a world whose plant life possessed
no other color.
  Somewhere, just a short time
before the close of the Age of
Reptiles, there occurred a
soundless, violent explosion. It
lasted millions of years, but it was
an explosion,  nevertheless. It
marked the emergence of the
angiosperms—the flowering plants.
Even the great evolutionist, Charles
Darwin, called them "an
abominable mystery," because they
appeared so suddenly and spread
so fast.
  Flowers changed the face of the
planet. Without them, the world we
know—even man himself—would
never have existed. Francis
Thompson, the English poet, once
wrote that one could not pluck a
flower without troubling a star.
Intuitively he had sensed like a
naturalist the  enormous interlinked
complexity of life. Today we know
that the appearance of the flowers
contained also the equally
mystifying emergence of man ....
  Slowly, toward the dawn of the
Age of Reptiles, something over
two hundred and fifty million years
ago, the little  naked sperm cells
wriggling their way through dew
and raindrops had given way to a
kind of pollen carried by the
wind .... Instead of spores (a
single cell fertilized in the
                                                                                         EPA JOURNAL

  beginning by a swimming sperm)
  simple primitive seeds carrying
  some nourishment for the young
  plant had developed, but true
  flowers were still scores of millions
  of years away. After a long period
  of hesitant evolutionary groping,
  they exploded upon the world with
  truly revolutionary violence.
   The event occurred in Cretaceous
  times in the close of the Age of
  Reptiles. Before the coming of the
  flowering plants our own ancestral
  stock, the warm-blooded mammals,
  consisted of a few mousy little
  creatures hidden in trees and
  underbrush. A few lizard-like birds
  with carnivorous teeth flapped
  awkwardly on ill-aimed flights
  among archaic shrubbery. None of
  these insignificant creatures gave
  evidence of any remarkable talents.
  The mammals in particular had
  been around for some millions of
  years, but had remained well lost
  in the shadow of the mighty
  reptiles. Truth to tell, man was
  still, like the genie in the bottle,
  encased in the body of a creature
  about the size of a rat....
   Neither the birds nor the
  mammals, however, were quite
  what they seemed. They were
  waiting for the Age of Flowers.
  They were waiting for what
  flowers, and with them the true
  encased seed, would bring ....
   When the first simple flower
  bloomed on some raw upland late
  in the Dinosaur Age, it was wind
  pollinated, just like its early
  pine-cone relatives. It was a very
  inconspicuous flower because it
  Loren Eiseley. Copyright (c) 1957 by
  Loren Eiseley. Reprinted by permission
  of Random House, Inc.
had not yet evolved the idea of
using the surer attraction of birds
and insects to achieve the
transportation of pollen. It sowed
its own pollen and received the
pollen of other flowers by the
simple vagaries of the wind. Many
plants in regions where insect life
is scant still follow this principle
today. Nevertheless, the true
flower—and the seed that it
produced—was a profound
innovation in the world of life ....
  But the seed, unlike the
developing spore, is already a fully
equipped embryonic plant packed
in a little enclosed box stuffed full
of nutritious food. Moreover, by
featherdown attachments, as in
dandelion or milkweed seed, it can
be wafted upward on gusts  and ride
the wind for miles; or with  hooks it
can cling to a bear's or a rabbit's
hide;  or like some of the berries,  it
can be covered with a juicy,
attractive fruit to lure birds, pass
undigested through their intestinal
tracts and be voided miles away.
  The ramifications of this
biological invention were
endless .... The well-fed, carefully
cherished little embryos raised
their heads everywhere. Many of
the older plants with more
primitive reproductive mechanisms
began to fade away under this
unequal contest. They contracted
their range  into secluded
environments. Some, like the giant
redwoods, lingered on as relics;
many vanished entirely.
  The world of the giants was a
dying world ....
  On the edge of the forest, a
strange, old-fashioned animal  still
hesitated. His body was the body of
a tree dweller, and though tough
and knotty by human standards, he
was, in terms of that world into
which he gazed, a weakling ....
  He was a ne'er-do-well, an
in-betweener. Nature had not done
well by him. It was as if she had
hesitated and never quite made up
her mind. Perhaps as a
consequence he had a malicious
gleam in his eye, the gleam of an
outcast who has been left nothing
and knows he is going to have  to
take what he gets. One day a little
band of these odd apes—for apes
they were—shambled out upon the
grass; the human story had begun.
  Apes were to become men, in the
inscrutable wisdom of nature,
because flowers had produced
seeds and fruits in such
tremendous quantities that a new
and totally different store of energy
had become available in
concentrated form.
    Editor's Note:
    The comments of Loren Eiseley's
    colleagues, who personally knew
    the famed anthropologist at the
    University of Pennsylvania be/ore
    his death in  1977, shed little light
    on the genius in their midst.
      Pleasant ... a bit shy, they said
    to EPA Journal in telephone
    conversations. Didn't like students
    button-holing him after
    lectures .... Quite an attractive
    fellow—tall,  brown hair, brown
    eyes. The curriculum vitae  on
    Eiseley explains him no
    better—born  in 1907 in Nebraska,
    son of a hardware salesman,
    bookish, liked literature,
    poetry .... a

      by Miles Kahn
     (Kahn is a Pufa/ic Affairs
     Specialist with EPA's Office of
     Radiation Programs.]
   Four EPA scientists visited the
   Soviet Union last summer,
where they participated with
Soviet scientists in a
radiological assessment survey of
the Northern Black Sea
environment. In addition to
samples of sediment, water, and
marine life, they brought back an
appreciation of the growing
environmental movement in the
Soviet Union.
  The Black Sea survey was
carried out under the auspices of
the U.S.-U.S.S.R. Joint Committee
on Cooperation in the Field of
Environmental Protection,
established in 1972. The survey,
which is the first
radiation-related project
conducted under the agreement,
is also the first environmental
project under this cooperative
arrangement that is directly
related to the 1986 Chernobyl
disaster—still a subject of great
concern in the Soviet Union.
  The survey did more than
increase the knowledge of the
Soviets and others of the
long-term environmental and
ecological effects of Chernobyl. It
has given scientists a unique
opportunity to study how a large
inventory of radioactive materials
from an actual accident at a
nuclear-power facility moves
through and is ultimately
distributed in freshwater and
marine ecosystems. The survey is
the first part of a program that
will eventually provide a more
comprehensive understanding of
how accident-related radioactive
materials move from a source
(Kiev) to a final destination (the
Black Sea) several hundred miles
  Through this program,
scientists will better understand
which radioactive materials flow
through waterways, which stick
to bottom sediments along the
way, and which ultimately
become deposited in and
distributed throughout a distant
marine environment. From such
information, experts can
construct more accurate
environmental transport models
that predict radionuclide
movement and deposition for
different accident scenarios. The
models, in turn, will help
develop long-term monitoring
plans to assess radiation releases.
  Further, results from the
overall program could help
develop remediation and
clean-up strategies. The
strategies, for example, could be
used if the sediment in a
reservoir  or river used as a
drinking-water source were
disturbed by storms or dredging
that dispersed radioactive
materials deposited  as a result of
a nuclear accident.
  The initial phase of this
ambitious program was
conducted from June 12 through
June 23, 1990, aboard the Soviet
research vessel Vodyanitskiy,
sailing from Sevastopol on the
north central coast of the Black
Sea. The  Vodyanitskiy was made
available  to EPA by the primary
Soviet participating organization,
the Ukrainian  Academy of
                                                                                                    EPA JOURNAL

                                                                                                The Chernobyl
                                                                                                Nuclear Power
                                                                                                Station in Kiev,
                                                                                                where a 1986
  Science's Institute of Biology of
  the Southern Seas (IBSS), headed
  by Dr. S. M. Konovalov.
    Two days prior to sailing, the
  American contingent—consisting
  of Bob Dyer, Bill Curtis, Jim
  Neiheisel, and Jon Broadway
  from EPA's Office of Radiation
  Programs—arrived in Sevastopol.
  There they met with their Soviet
  counterparts, coordinated survey
  activities, and prepared the ship.
  In addition to the four EPA
  scientists, the group included
  radiochemist Hugh Livingston
  and three other scientists from
  the Woods Hole Oceanographic
  Institution (WHOI) who
  participated as co-investigators in
  this EPA project. Florence
  Harrison, expert on radiation
  effects on marine organisms from
  Lawrence Livermore National
  Laboratory, completed the
  American Group.
    While in Sevastopol, the
  Americans stayed aboard the ship
  since the city had  no hotels for
  foreigners. Because of its naval
  installations, until recently
  Sevastopol was closed even to
  Soviet visitors. And although
  things are changing there, tourists
  and foreign visitors still must
  enter the city through a military
  checkpoint and are limited to day
trips. In contrast to this situation,
dramatic evidence of a changing
atmosphere was provided in the
summer of 1989 by a visit to the
city by U.S. Navy ships—the first
in over 40 years.
  On the morning of June 12, the
215-foot, 1,200-ton Vodyanirskiy,
with EPA's Curtis, Neiheisel, and
Broadway and the WHOI
scientists on board, sailed into
the Black Sea to begin collecting
water, sediment, and marine-life
samples. The daily scientific
work was  conducted to coincide
as much as possible with the
ongoing studies of the Soviet
scientists. Most of the voyage was
spent in the northern part of the
Black Sea because that is the area
into  which the Dnepr River
system flows. The Dnepr was the
major water pathway for
radioactive materials from the
Chernobyl accident.
  The collection of subsurface
water samples for cesium and
strontium analyses—to determine
the levels  of radioactive materials
still  present—required large
volumes of water. This was
collected by pumping deep water
to the surface via  hoses and using
specialized, cylindrical
Bodman-bottle water samplers,
each one capable  of holding
     Wide World photo.

about 25 gallons of water. After
the bottles were lowered to a
specific depth,  seawater from that
depth was collected and the
bottles were hauled back to the
ship's deck. Surface water
samples were collected by using
floating pumps. All these water
samples are being separately
analyzed by the IBSS and the
WHOI Chemistry Department.
  Sediment samples were taken
with a box corer, an
EPA-furnished  piece of
equipment. The
rectangular-shaped box corer
enabled the scientists to collect,
in one operation, the number of
undisturbed subcores needed to
conduct all the required analyses.
  The sediment samples are
being analyzed to determine
overall radioactivity levels, how
specific radioactive materials
move through the sediment, what
the mineralogical makeup is and
how this affects radionuclide
movement, what the heavy metal
content is, and what biological
organisms are present that also
could redistribute radioactive
material. Samples are being
analyzed by EPA's National Air
and Radiation Environmental
Laboratory in Montgomery,
Alabama; the IBSS; WHOI;

                   Hill Curtis phnlo.

                   Brookhaven National Laboratory;
                   the Moscow Academy of
                   Sciences; and the U.S. Army
                   Corps of Engineers.
                     The third scientific activity,
                   biological sampling, consisted of
                   lowering samplers to obtain
                   mussels and other
                   bottom-dwelling invertebrates
                   and also trawling to collect
                   bottom and near-bottom fish.
                   Because of unique conditions
                   existing in the Black Sea—below
                   300 to 400 feet the sea cannot
                   support marine life because there
                   is no oxygen in the
                   water—biological sampling for
                   the survey was limited to
                   locations with shallow water.
                   The biological samples are being
                   analyzed by EPA at its
                   Montgomery laboratory, by the
                   IBSS, and by WHOI.
                      As a  follow-up to the analysis
                   of the water, sediment, and  biota
                   samples, the results will be
                   shared  among the laboratories as
                   part of a program to compare
                   data and methods and establish
                   quality assurance. The initial
                   results  of the Black Sea survey
                   are expected by summer 1991.
                      The shipboard experience
                   could not have been smoother.
                   According to Curtis, EPA
scientific team leader and a
veteran oceanographer, "The
VodyanitsJdy is comparable to
most U.S. oceanographic research
vessels, and the level of
cooperation and professional
respect among the scientists was
exceptional." Also, enough of the
Americans spoke  Russian, and
vice versa, so that there were
virtually  no communication
problems between the U.S.
visitors and the onboard Soviet
scientists and crew. As a result,
the U.S. and Soviet scientists
established some  strong
professional and personal
relationships that auger well for
successful completion of the
proposed second  phase of this
  That second phase of the
Chernobyl-related cooperative
program involves  studying the
movement of accident-generated
radioactive materials from the
Kiev reservoir down the Dnepr
River to the Black Sea. The
Ukrainian city of  Kiev, the Soviet
Union's second largest city, is
just 65 miles south of Chernobyl.
Before  the Vodyanitskiy set sail,
two EPA  scientists, Dyer and
Broadway, met with  officials and
scientists in Kiev  to discuss plans
for a second phase.
                                                                                      Biological sampling
                                                                                      was part of the
                                                                                      work undertaken by
                                                                                      the Black Sea
                                                                                      survey team.
  At that time, they gained an
appreciation of the concern
expressed—and actions
taken—by local scientists and
residents over their continual
exposure to radiation from
Chernobyl. For example, all
Kiev's grass clippings and leaves
were collected during the
summer and fall following the
1986 accident and buried in a
large excavation  to isolate the
radioactive contamination. The
Kiev newspaper  still issues
weekly reports on radioactivity
levels in the vicinity. Last June 2,
there was even a television
call-in show for Kiev residents to
ask questions about radioactivity
from Chernobyl.  The Director of
the Kiev Water Supply and
Wastewater Treatment Agency
wants Kiev declared a zone of
ecological disaster. From what
Dyer observed, such activity is
part of a very real environmental
movement that did not exist in
the Soviet Union, even two years
  The momentum of the Soviet
Union's environmental
movement is  further evidenced
by the unprecedented
participation  of a
non-government  Soviet
environmentalist in the  12th
formal meeting of the
U.S.-U.S.S.R.  Joint Committee
hosted by EPA at its Washington,
DC, headquarters in 1990. We are
looking forward to increased
levels of participation by more
segments of Soviet society,  not
only in the study of radiation and
its effects, but in all important
environmental areas, n
                                                      EPA JOURNAL

ON the  MOVE
 EPA's Water Office has
 undergone a major
 restructuring, announced
 recently by Lajuana
 Wilcher, Assistant
 Administrator for Water.
 The purpose of the
 reorganization is to put  a
 greater emphasis on
 pollution prevention and
 ecological risks, which
 will include targeting
 specific geographical
 regions. The following is a
 summary of key
 appointments in the

 Martha G. Prothro is the
 new Deputy Assistant
 Administrator for Water.
   Her professional federal
 government service began
 in 1965, when she served
 in a variety of positions in
 a  federally sponsored
 demonstration program
 assisting welfare recipients
 in obtaining work,
 training, and experience in
 the District of Columbia.
 Prothro began her  career at
 EPA as an attorney in the
 Office of Enforcement and
 General Counsel in 1973.
 She worked in the
 Stationary Source Air
 Enforcement Program until
 1980, serving as a  staff
 attorney, as a section chief,
 and beginning in 1977, as
 Chief of the Enforcement
 Proceedings Branch in the
 Division of Stationary
 Source Enforcement.
   Prothro joined the
 Senior Executive Service
 in 1980, when she became
 the Director of the Noise
 and Radiation Enforcement
 Division.  One year later,
 she was named the
 Director of the Permits
 Division,  within the water
 program. She served as
 Acting Director of  the
 Office of Water
 Enforcement and Permits
 in 1982 and became the
 Director of the Office of
Water Regulations and
Standards in 1988.
  A 1965 graduate of the
University of North
Carolina, Prothro  earned a
JD from George
Washington University's
National Law Center in

Robert H. Wayland  HI is
the new Director of  the
Office of Wetlands,
Oceans, and Watersheds,
which is responsible for
policy and  management;
the Office also provides
support to regional and
state programs to  prevent
and control nonpoint
source pollution,  the
assessment and monitoring
of the health of the
nation's waters, coastal
and ocean protection
programs, and  the
wetlands program.
  Prior to his current
position, Wayland was
Deputy Assistant
Administrator for Water.
Before joining the Office of
Water, he was  the Deputy
Assistant Administrator for
EPA's Office of Policy,
Planning, and Evaluation
from January 1988 to
November 1989. Wayland
was a Special Assistant to
EPA  Administrator Lee M.
Thomas and Deputy
Administrator A.  James
Barnes and was
responsible for providing
independent counsel to
them on issues involving
several EPA programs,
including those
administered by the Office
of Water. He also  held
positions in EPA's Office
of Enforcement and  the
Office of Solid Waste and
Emergency  Response; he
came to EPA in 1974,
when he joined the
Agency's Congressional
Affairs staff.
  Prior to his EPA career,
Wayland held positions in
the U.S. House of
Representatives and Senate
as well as the National
Transportation Safety
Board. He has also served
as a Planning
Commissioner in the City
of Falls Church and was a
member of the
Architectural Review
Board in that community.
  Wayland is a graduate of
the George Washington
University  in Washington,
DC, and is a recipient of
EPA's Gold Medal for
Exceptional Service.

Michael B. Cook is the
new Director of the Office
of Wastewater
Enforcement and
Compliance, which is
responsible for issuing and
enforcing permit controls
on municipal and
industrial wastewater
discharges. In addition, it
administers federal
financial and technical
assistance for publicly
owned wastewater
treatment works.
  Cook joined EPA in 1973
and worked in several
positions in the
Construction Grants
Program for municipal
wastewater treatment
facilities. In 1980 and
1981, Cook managed EPA's
emergency response
program, including early
implementation of the
Superfund  legislation.
From 1981 to 1985 he was
the Deputy Director of the
Office of Solid Waste.
Cook became the Director
of the Office of Drinking
Water in 1985 and served
there until  his  current
  Cook served in the
program in Vietnam and as
a consul with the Foreign
Service in Northeast
Thailand. He also worked
for HUD in the Model
Cities Program.
  He received a bachelor
of arts degree in political
science from Swarthmore
College in 1963 and earned
a bachelor of philosophy
degree in political science
from Oxford University in
1966. Cook has received
numerous awards,
including EPA's gold,
silver, and bronze medals.
He also received the
Distinguished  Executive
Award from President
Reagan in 1987.

The  new Director of the
Office of Science and
Technology  is Tudor
  Prior to his current
position, Davies  served as
the Office of Water's
Director for the Office of
Marine and Estuarine
Protection for seven years.
Within the Office of Water,
he has also been the
Director of the Office of
Program and Management
Operations in 1983.
  He joined  EPA in 1972
and worked  in the Office
of Research and
Development. He was the
Deputy Laboratory Director
of the Gulf Breeze
Environmental Research
Laboratory from  1975 to
1979; subsequently, he
became the Director of the
Environmental Research
Laboratory from  1979 to
1983. He also served as
Director of the Chesapeake
Bay Program from 1979 to
  Davies attended the
University of Wales in
Swansea and earned both a
bachelor of science degree
and a doctorate in geology.
He was a Postdoctoral
Fellow at Dalhousir
University in Canada.
Before joining EPA, he was
an Associate Professor of
Geology at the University
of South Carolina.
  He was a recipient of the
Presidential Meritorious
Executive Award in 1989.

James R. Elder has been
named the new Director of
the Office of Ground Water
and Drinking Water.
  Prior to his recent
appointment, Elder has
held several positions
within EPA going back to
1971. Most recently, Elder
was the Director of the
Office of Water
Enforcement and Permits
within the Office of Water
for five years. Transferring
from the Office of
Management and Budget,
his first position at EPA
was as management
analyst in the Office of
Planning and Management
and then as the Assistant
to the then Assistant
Administrator Al Aim in
1974. From 1975 to 1979
he  was the Director of the
Management Division for
Region 3 in Philadelphia.
  As part of the
President's Executive
Exchange Program, he
served for one year as the
Executive Assistant to a
senior vice president at the
Potomac Electric Power
Company. Elder  returned
to EPA to become the
Deputy Director  of the
Office of International
Activities. In 1983, he
moved to the Water
Program  to  become Deputy
Director of the Office of
Water Enforcement and
Permits. In  198ti  he was
detailed as the Acting
Deputy Regional
Administrator for Region
10 in Seattle.
  Elder is a 1967 graduate
of Johns Hopkins
University with a bachelor
of arts degree in
international relations. He
also attended George
Washington University in
1969, where he studied
international affairs.

ON the  MOVE
 In the Office of General
 Counsel, Charles L. K Ik ins
 is the new Senior Counsel
 to the General Counsel,
 specializing in legal
   Elkins' environmental
 career began in 1967 as the
 budget examiner for
 Environmental Health  in
 the Office of Management
 and Budget. In that
 position he played a
 principal role in  the
 creation of EPA in 1970.
 He then joined the Agency
 as a special assistant to
 Administrator William
 Ruckelshaus in 1971. One
 year  later, he  became the
 Principal Deputy to the
 Assistant Administrator for
 Categorical Programs,
 which included pesticides,
 solid wastes, radiation,
 toxic substances, and
 noise. From 1973 to 1974,
 Elkins was the Acting
 Assistant Administrator for
 Hazardous Waste Control.
 He then served as the
 Senior Budget Officer  for
 the Office of Water and
 Hazardous Materials until
 he became the Director of
 the Noise Control Program
 from 1975 to 1981.  During
 that time, he was also  the
 Executive Director of the
 Commission on Fiscal
 Accountability of the
 Nation's Energy Resources
 for the Department  of  the
   From 1982  to 1983,
 Klkins was the Senior
 Budget Officer for the
 Office of Air and Radiation
 (OAR). He served as the
 Acting Assistant
 Administrator for Air and
 Radiation for  six months
 in 1983, then again for one
 year  in 1985.  Between
 those positions, he  was
 OAR's Director of Program
 Development. Elkins was
 the Director of the Office
of Toxic Substances from
1986 until his current
  Elkins received a
bachelor of arts degree in
philosophy from Yale
University in 1962 and a
JD in 1967 from Yale Law
School. He was a recipient
of the EPA Gold Medal in
1972 and the Presidential
Award for performance in
The new Deputy Director
of the Office of Air Quality
Planning and Standards
within the Office of Air
and Radiation (OAR),
Research Triangle Park,
North Carolina, is Lydia N.
Wegman. Wegman began
her career with EPA in
1977 as an
attorney-advisor to the
Office of General Counsel.
Four years later, she
became an Acting
Assistant General Counsel
within the same office. She
was a special assistant to
the Director of Mobile
Sources from 1985 to 1987.
Her most recent position
was as the Senior Legal
and Policy Advisor to the
Assistant Administrator for
the OAR.
  Between various EPA
positions, Wegman was a
legal assistant for the
President's Office at the
University of Iowa in  1987,
where later that same year,
she became an
Immigration Specialist for
the Office of Finance and
University Services. She
was also an associate at
the Law firm of Swidler,
Berlin and Strelow from
1982 to 1985.
  A 1971 graduate of Yale
University, she received a
bachelor of arts degree in
history. She then  earned a
JD from Columbia Law
School in 1976. Wegman
has been a recipient of the
Group Gold Medal for
Exceptional Service in
1989 for outstanding work
on the Clean Air Act
Amendments and the EPA
Group Silver Medal for
superior work in
developing regulations to
prevent significant
deterioration of air quality
in clean air areas.
Richard D, Morgenstern
has been named the new
Acting Assistant
Administrator for the
Office of Policy, Planning,
and Evaluation (OPPE).
The former OPPE Deputy
Assistant Administrator
will take the position most
recently held by Dan
Beardsley. Prior to that, he
served as OPPE's Director
of the Office of Policy
Analysis, a position he has
held since 1983.
Morgenstern has served as
Executive Director of the
Agency's Task Force on
Global Climate Change and
co-chaired the Agency's
Economic Incentives Task
Force. In 1981 he was the
leader of the task force that
produced Unfinished
  Before joining EPA,
Morgenstern held a
number of positions inside
and outside of
government. From 1971 to
1976, he was a tenured
associate professor of
economics at Queens
College. He then became
the Deputy Assistant
Director for Energy,
Natural Resources, and the
Environment for the
Congressional Budget
Office in 1976. From 1979
to 1980 he served as a
senior legislative assistant
for Senator J. Bennett
Johnston. In 1980, he
became the Director for the
Energy Program at the
Urban Institute.
  A 1966 graduate of
Oberlin College,
Morgenstern received a
bachelor of arts degree in
social science. Four years
later, he earned a doctorate
in economics from the
University of Michigan.
  The new Director of
Technical Assistance and
Soviet and East European
Affairs for the Office  of
International Activities is
Dan Beardsley.
  Beardsley joined EPA in
1980 as a program analyst
for the Integrated
Management Division
within the Office of Policy,
Planning, and Evaluation
(OPPE); he became
director of that  division in
1982. From that position,
he became  OPPE's Director
of the Regulatory
Integration Division in
1986. Beardsley was
named OPPE's Deputy
Assistant Administrator for
Policy, Planning, and
Evaluation in 1989 and
served  as Acting Assistant
Administrator from March
1, 1991, to  his present
  Beardsley began his
career as a  chaplain at the
University of Florida in
1968. From 1972 to 1977,
he managed drug
treatment programs for the
City of Atlanta and the
State of Georgia. He moved
to Washington, DC, to
become assistant to the
Director of the ACTION
Agency, which  includes
VISTA and the  Peace
  A 1966 graduate of
Kalamazoo College,
Beardsley received a
bachelor of arts degree in
philosophy. In 1972 he
earned a master's in
divinity from Yale
                                                                                                                     EPA JOURNAL

  © 1985 Universal Press Syndicate
                 "The picture's pretty bleak, gentlemen. ... The
             world's climates are changing, the mammals are
                 taking over, and we all have a brain about
                           the size of a walnut."
      The Far Side. Copyright 1985. Universal Press Syndicate. Reprinted with permission. All rijififs reservei
                                                                                   Back cover: A decent
                                                                                   environment, the nation's
                                                                                   goal. Photo by Pat Lanza for
                                                                                   Folio, Inc.