Student Manual
                            HEADQUARTERS LIBRARY
                            ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, D.C. 204SO


                 Prepared for:
       U.S. Environmental Protection Agency
      Office of Policy, Planning and Evaluation
               Washington, D.C.
                 Prepared by:
         Clayton Environmental Consultants


                                  Table of Contents


Introduction/What Do We Mean by Risk Communication?	I

Overview of Risk Assessment, Risk Management, and Risk Communication— n

Maijol Superfund Site	in

Dealing with the Media/Handling Tough Questions	IV

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Planning for Risk Communication	VI

ASARCO Case Study	VH

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              Environmental Protection Agency
                Risk Communication Training



Introduction/What Do We Mean by Risk
Risk Assessment, Risk Management, and Risk
Marjol Superfund Site
Dealing with the Media/Handling Tough
Explaining Technical Issues
Review of Day 2
    Day 2
Planning for Risk Communication
Review of Materials in Case Study
Begin Preparation for Role Play
- Planning
- Draft Opening Statements
Extended Lunch and Role Play Preparation
Role Play





   Development of the Workshop

       The ability to communicate effectively with the public (and other government officials)
on issues of risk and to involve the public meaningfully in decision making have long been
Agency goals.  In 1989, the Office of Policy Planning and Evaluation (OPPE) completed work
on a two-day workshop designed to train Headquarters and Regional personnel in the
principles of effective risk communication.  The workshop was designed to complement (but
HOI replicate) the OPPE course on risk assessment and risk  management entitled "Risk and

       Between 1989 and 1992, the workshop and modified versions of it have been given to
over 2,500  state and federal employees. Modified versions of the course have been prepared
to meet the specific needs at several offices at EPA including the Superfund Office, the
Chemical Emerging Planning Preparedness Office, the Office  of Pesticide Programs, the Office
of Radiation Programs, and the Air Risk Information Center in Research Triangle Park.

       OPPE decided to revise and update its course, in 1992. Accordingly, the office has
sought opinions on changes to be made and new material to be included  from Headquarters
and Regional personnel who have taught or taken the course and from those involved in public
affairs and other risk communication activities. OPPE sought information concerning the
elements of the course that should be eliminated or removed, suggestions for additions to the
course and on other potential improvements.  This revised manual reflects many of the
suggestions received during this process.

   Structure of the Workbook

      This workbook is designed to guide you through the two day workshop. Each section
consists of a brief introduction outlining the issues to be discussed, brief descriptions of
videotapes and other material that will be used during that section, related background
information, potential discussion questions, and additional  readings that  are in the Resource
Document.  The workbook also contains background information necessary for the role play
and communication planning exercises.

      The Resource Document, which is included at the back of the workbook is a
compendium of articles, brochures, pamphlets and other material, that address various risk
communication issues.
RISK Communication Workshop                                          Introduction - 1

             Goals and Objectives
      The workshop has been designed to introduce the principles of effective risk
communication and to give you the opportunity to put the principles into practice. It will
consist of video clips, case studies, role playing, and some overhead presentations. You will
be given a great deal of opportunity to participate actively during the workshop and for the
workshop to be successful, you must take advantage of it.  The primary goals and objectiv
for the program are set forth below:

   *  Discuss the rationale for being concerned about risk communication

   •  Discuss the various purposes of risk communication:

       -  Most immediately, to inform and involve the public productively in decision

       -  More generally, to raise the  level of public discussion about risks to the
          point where the nature and severity of the risk is generally understood and
          the discussion can focus on issues of values, the distribution of costs and
          benefits, etc.

   •  Discuss a number of communications options:  use of news media, public
      meetings, focus groups, and written communications.

   *  Develop practical guidelines for more effective communication about chemical
      risks and to give participants practice in using these guidelines.
             Discussion  Questions - Participant Expectations
   1.  What are your goals/objectives for the workshop?
   2.  What questions do you have that you hope we can address?
Risk Communication Workshop
                                                                 introduction - 2

             Video Segment - Opening Collage
      The first set of clips shows examples of a number of issues that will be discussed
during the workshop. Included among these are the presence of uncertainty in risk
communication, the importance of body language on communication, questions of trust and
credibility, the difficulty of explaining technical questions and the role of non-technical issues
in risk debates.  This latter point is illustrated by the presence of Meryl Streep, who was
involved in the Alar crisis.

      As you  watch the clips, consider the issues noted above. How are risks described?
Do you like the risk comparisons you saw. What is your view of the role of the media as
represented by  the Donahue clip?  Finally, what is your reaction to seeing Meryl Streep
representing an environmental group? What is her role? Is it appropriate?
             Definition of Risk Communication
      The National Academy of Sciences defines risk communication as "an interactive
process of exchange of information and opinion among individuals, groups and institutions."
A key element of this definition is that it is an exchange of information among parties, not a
one-way flow of information.

      EPA recognizes the need not only to impart information in a comprehensible manner
but also to provide the public with the opportunity to become involved. The purpose of risk
communication is not to allay the public or merely help them see your point of view. As
former Administrator Lee Thomas noted in discussing community relation efforts in
Superfund, "We are not going to go into a community and tell people what we intend to do.
We are going to listen to local concerns and ideas. It is true that many of the issues involved
in a site cleanup are highly technical, but we can no longer use that as an excuse for
discounting what a community has to say about risk.  We must empower the community to
discuss risk in a rational and technically competent way."

      It must be pointed out that there is no single public. There are many different publics,
including, but not limited to, the regulated community, individuals living in the area,
environmentalists,  and politicians.
Risk Communication Workshop                                         Introduction - 3

             Video Segment • New Jersey Meeting
             Discussion Questions - What Do We Mean By
             Risk Communication?
      What is the relationship between your office and "the public"? Is the
      relationship as strong as it can or should be?  (Refer to the Ladder of Citizen
      participation developed at Rutgers, and included in the resource section of
      this manual on page 31) Does your office deal with the "public"

      It is important to note in different situations, the role of the public will be
      different.  The latter does not imply that public participation should be at the
      top.  (Government actions are often at the inform stage; but is usually
      characterized by Consult 1.) You have to be clear about what you mean by
      public participation. Don't mislead the community about the role they can play.
      You should try to find out where they want to be and, if possible try to get
      them there.
   2.  What are the characteristics of the ideal public? Suppose you were going to a
      public meeting, or an informed gathering, what are die characteristics of the
      people you'd like to see there?
   3.  What can you, as government officials, do to get people to behave the way
      you've said you want?
Risk Communication Workshop
Introduction - 4

            Additional Readings in Resource Section -
            Introduction to Risk Communication
   •  The Seven Cardinal Rules of Risk Communication, p. 1

   •  Risk Communication Problems and Tasks, p. 7

   •  Some Do's and Don'ts of Listening, p. 9

   •  Improving Dialogue with Communities: A Short Guide for Government Risk
      Communication, p. 13

   •  Ladder of Citizen Participation: p. 31

   •  Ten Ways to Lose Trust and Credibility, p. 45
Risk Communication Workshop                                    Introduction - 5




            Risk Assessment, Risk Management, and Risk

      Hie following slides will form the basis for an overview of risk communication issues
and how risk communication fits in with risk assessment and risk management. We will also
discuss a definition of "risk" that includes both risk assessment data and other factors that
affect the way people perceive risk.

      Clearly this presentation is not intended to make you risk assessors.  Rather, it is
designed to help you understand the assessment process that produces the "numbers" used
in describing risk.  By understanding what goes into this number you will be better able to
explain what it means to the pubb'c.  Finally, we will introduce, through these slides, some
thoughts on planning and evaluation of risk communication efforts. This will be discussed in
more detail in Chapter V.
            Video Segment - Broader Definition of Risk
      At the end of the overheads, a brief video will be shown. The clip is of Dr. Peter
Sandman of Rutgers discussing his notion of the need for a broader definition of risk. For
more background, the reader is referred to the article he wrote for EPA and which is included
in the resource document on p. 115. The article is entitled "Explaining Environmental Risk:
Some Notes on Environmental Risk."
            Additional Readings in Resource Section -
            Overview of Risk Communication
   •  Letter from Lee Thomas to Congressman Waxman on Relative Risk, p. 47

   •  Differences Between Expert and Public Ratings of Environmental Problems.
      p. 55

Risk Communication Workshop           Risk Assessment, Management, and Communication-1





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      The next section of the course deals with a public meeting held in July 1988 on the
progress of clean-up activities at a Superfund site in Pennsylvania. The site is at the Marjol
Battery Plant where, for many years, lead batteries had been split open (and the lead re-
processed) and the broken casings - with some lead remaining - had been dumped into a
landfill. As a result of activity at the plant and soil dispersion from the dump site, many
homes near the site have elevated levels of lead in their soil. The high lead poses a special
risk to children, who come in greater contact with the exposed soil through their play and who
are more susceptible to risks posed  by elevated lead levels.

      The high lead levels at the site have been known since the late 1970's and recently
EPA has begun remedial action.  The meeting was the second one held in the area since
January 1988.  The site was not on the Superfund's  National Priority List (NPL) at this time
and was being handled by the on scene coordinator.

     •      ~  Video  Segment -  Marjol Superfund Site
       The first segment of the Marjol tape is from a televised "town meeting" held in
September. This brief segment of tape gives some background on the situation at the site.
As you watch the first piece of tape, keep in mind what "outrage factors" would be driving the
citizens of the community.  Since the problem has been going on for some time, there is likely
to be mistrust between the community and the EPA and state Agencies involved in the clean-
up activity. Also, the higher risk posed to children will increase outrage associated with the
question of fairness.

       The second pan of this segment shows the Superfund On  Scene Coordinator (OSC)
addressing the audience.  The meeting occurred in July 1988 when it was very warm, and
began with a long rather technical discussion before the site coordinator began. As you
watch the tape keep the following questions in mind:
Risk Communication Workshop                                                 Marjol-1

              Discussion Questions  -  Marjol Superfund Site
      The EPA Regional Administrator had, on the advice of the on-scene coordinator,
      recently sent a letter to the residents which included some inaccuracies concerning
      earlier blood levels of lead in the area. This has lead to a great deal of consternation
      among the citizens and town leaders. How does the OSC handles this matter and
      respond to concerns raised by the letter?
   2.  What were the EPA representative's expectations and goals for the meeting? Were
      they reasonable?
   3.  What is your reaction to his declaration that he wants .to allay the citizen's concerns?
      Is this effective?
   4.  Is the EPA representative effective when he notes that he has only seen one other
      site, at which there turned out to be a real health risk, and now this site may make
   5.  What is your reaction to his relationship with the audience?  Referring back to the
      Ladder of Citizen Participation (see p. 33), how is he dealing with the public?
Risk Communication Workshop
Marjol- 2

             Video Segment - Marjol Superfund Site
      The next tape shows a heated discussion between the OSC and a woman in the
audience. The woman is clearly upset about the fact that her children had high blood lead
levels in the late 1970's, and she feels that not enough was done about it. One of her children
has a learning disability and it is clear that in her mind the lead is responsible. Clearly, she is
angry and wants to vent some of her aggression at those she feels are giving her the bum's
rush. - She starts in by saying that the EPA and state officials, because they are  educated,
would never live in the area while the remediation work is being done.
      Her first question is straight forward and hard hitting - "why should we believe you
             Discussion Questions -Marjol Superfund  Site
   1.  Ignoring the specifics of this case, consider how you would respond. What do you say
      to someone who flat out says he/she doesn't believe what you're saying?
   2.  What is driving this woman's outrage? Knowing that, how would you change your
      response to her question?
             Video Segment - Marjol Superfund Site
      The next and final segment of tape shows a continuation of the woman's questioning
of the OSC. Are you man enough, she challenges him, to tell us the truth? As you watch his
response, keep the questions on the following pages in mind.
Risk Communication Workshop
Marjol- 3

              Discussion Questions - Marjol Superfund  Site
    1.  Did the site coordinator adequately address the woman's concerns?  Could he have,
       given the confrontational manner of her questioning?
   2.  What guidelines can you develop to help you deal with situations in which you find
       yourself in confrontation with the audience?
   3.  What was the EPA representative attempting to accomplish during the meeting?
       What did the citizens (or at least those that we saw on the clips) hope to accomplish?
   4.  What is your reaction to the OSC's body language?  The room arrangement?
   5.  What should you do when your expectations of what should occur differ from the
      public's? What can you do prior to the meeting to decrease the possibility that this
      will take place? What can you do at the meeting? How could you find out the public's
RISK communication workshop
Marjol- 4

   6.  What are the key lessons to be gained from the Marjol tapes?

   •  Know your audience and their expectations

   •  Be sure to  tailor your own agenda and objectives to meet the public's

   •  Plan carefully and be aware that what you say will be filtered through the
      public's own perceptions

   •  Be aware of your body language and the messages it sends

   •  Listen carefully to the audience!  Tailor your responses to meet their concern

   *  If your objectives for the meeting are not the same as the audience's - do all
      you can  (even to the point of changing the nature of the meeting) to meet the
      public's needs.  In the long-run, you will have to address their concerns in order
      to get to yours.
             Additional Readings in Resource Section
             Marjol Superfund Site
   *  The Lethal Legacy of Lead Poisoning, p. 59
Risk Communication Workshop                                               Marjol- 5





      During this section of the course, we will discuss the role of the media in risk
communication efforts and will also review some ways to handle "tough" questions, whether
you get them during a media interview, at a public meeting, or at another forum.

      Our efforts here are obviously not meant to substitute  for the other types of training
available on how the Agency expects its personnel to deal with the media.  Still, there are
some lessons that can be easily reviewed concerning the way that you use the media and the
media uses you.

      You should remember that the need to meet the needs of the media is one of the
seven cardinal rules (#6). Among the guidelines stressed for  this rule are the following:

   •  Respect reporters' deadlines

   •  Provide information tailored to the needs of each type of media

   •  Follow up on stories with criticism or praise

   *  Try to establish long-term relationships with reporters
             Video Segment - Dealing with the Media
      The next video clip is of a presentation given by a San Francisco reporter (Tom Vacor)
at a Risk Communication conference in 1986. Do you agree with his key points? How could
the Agency do a better job with the media?

      A copy of his speech is included in the resource section (p. 63).
Risk Communication Workshop                                   Dealing with the Media-1

              Discussion Questions - Dealing with the Media
    1.  Is the media (print or television) your ally or your adversary in trying to communicate
       with the public?
   2.  How well/poorly does your office use the media? How can you use the media to
       communicate with the public and advance your goals?  Can EPA do what the public
       interest groups do in working with the media?
             Handling Tough Questions
      When faced with tough questions (during an interview, on the telephone, or at a public
meeting), it's often helpful to try to determine the type of question that is being asked in
order to avoid traps or pitfalls that may be laying for you. You shouldn't spend too much time
thinking about the kind of question - you do after all have to answer it.  However, it might be
helpful if you could identify what "underlies" the question.  This is an example of "ACTIVE
LISTENING", looking beyond the specifics of the question to identify the underlying
theme/objective of the questioner.

      In its course on Risk Communication and Public Involvement, EPA's Region IX
provides a list of 8 situations in which you might find yourself and some suggested
responses.  These "solutions" should not be  taken dogmatically but rather as suggestions.
Risk Communication Workshop
Dealing with the Media- 2

   1. The "set-up." A long preamble precedes a question, sometimes loaded with
      misinformation or a "when did you stop beating your wife" question.

      Example: "Considering the low regard that residents have for EPA, how do you, as
                part of EPA's team developing a permit for the ABC Industries facility,
                expect people to believe you are not selling out to ABC Industries?"

      Solution:  One solution, is to break in politely to challenge the premise. (Do not nod
                your head when the question is being asked - viewers will think you agree
                with what is being said.)  The second approach is to wait until the question
                is finished, then go back and knock down the preface: "Yes it may be true
                that some people are suspicious of EPA's negotiations with private
                companies, but in fact, the permit conditions for the ABC Industries facility
                requires extensive corrective action."  Or simply, "What you've said just
                isn't true. Let's look at the facts." - You may also want to concede that
                there may be cause for people to question what you're doing, but that they
                should look carefully at what you're doing now.

   2. The "either...or" situation.  The interviewer poses two unacceptable alternatives.

      Example: "Either you are misinformed, or you are protecting someone..." Another
                example: "Now were those irresponsible statements due to incorrect
                information or were they part of a deliberate attempt to mislead the

      Solution:  One solution is to answer the question  directly: "Neither.  The real issue
                here is..." and move on to the points you want to make.  Or you can just
                ignore the trap and respond the way you want.

   3. Irrelevancy.  In this situation, you are called upon to answer a question in an area
      unrelated to your area of expertise. As a result, you may be quoted out of context.

      Example: "Ms. Jones, as the EPA regional permit writer for the U-Dump landfill,
                what do you think EPA should include in the permit conditions for the
                Brown Industries storage facility?"

      Solution:  You might simply remark that it is not your area of expertise, then launch
                into some information regarding EPA's actions at the U-Dump landfill. -
                You may also want to direct them to someone who know more about the
                area they're questioning.
Risk communication Workshop                                    Dealing with the Media- 3

   4.  The empty chair situation.  In this situation, the interviewer quotes an opponent or
       person with a different point of view who has criticized your view, but is not present.

       Example:  "Dr. Ralph Smith has said that this facility is a serious health hazard."
                 Or, "Congressman X says EPA's handling of the permit application has
                 been inadequate."

       Solution:  You can respond simply "I have not heard those remarks," or "I believe
                 the facts will show..." You should make sure NOT to attack an opponent
                 who is not present. - Be willing to review the information and then comment
                 on it.

   5.  The broadside attack. This is the "ad hominen" argument, in which you are
       attacked directly.

       Example:  "You are deliberately withholding information aren't you?"

       Solution:  The best advice is to deny it straight out, if it is not true, or to be candid if
                 there is some truth in it:  "We only withhold information that we consider
                 confidential and which may adversely affect the drafting of a permit for a
                 facility." - You should also point out the ways (meetings, fact  sheets, etc.)
                 that you are attempting to get information out.

   6.  The hypothetical situation.  This technique involves the interviewer asking a
       hypothetical question - a "what if* question.

       Example:  "What if contamination is discovered in the ground water below the
                 facility?  Will EPA deny the permit application?"

       Solution:  The best advice is to point out that "we can't speculate on what we might
                 do until all the facts are in."  However, you should also note what you're
                 doing to ensure that you're gathering all the information.
Risk Communication Workshop                                    Dealing with the Media- 4

   7.  Inconsistency. If you or your organization has changed opinions or policies over time,
       you. might be asked about that change.

       Example: "When the facility's permit application was called in, EPA said it would
                notify the community or any deficiencies in the application.  But you found
                deficiencies and did not tell us."

       Solution:  You should clearly explain the reasons for the change, whether it was due
                to a change in policy or circumstance. For example, "Our intentions remain
                to keep the community well-informed as the permit is developed.  But the
                deficiencies we have found so far in the permit application are
                administrative and minor."

   8.  "No comment." "No comment" is not the same as "I don't know," "No comment"
       can be stated a number of ways. If you do not know  the answer to a question, state
       that you do  not know the answer.

       Example: "We have heard that ABC Industries, a large employer in the area, may be
                required to perform extensive corrective action to keep this facility in

       Solution:  If the answer  is "no comment," it can be done smoothly. For example,
                "EPA has not yet made a decision  about the extent of corrective action that
                will be required.  We will be sure to inform you as soon as we have reached
                a decision."
              Role Play - TV Interview  on Ethylene

      For the following small role play exercise, we will be looking at a case involving a
pesticide, ethylene dibromide - or EDB. The purpose of the exercise is to gain some
experience in dealing with the media and handling tough questions.  In addition, it's intended
to illustrate the importance of planning for an interview and dealing with it in accordance with
the  seven cardinal rules.

      For preparation, review the brief background piece on EDB that follows on p. 8 of this
Risk Communication Workshop                                   Dealing with the Media- 5

              Video Segment  • News Broadcast on EDB
       Watch the following clip, is from a news broadcast on the problem EDB might pose.
 As you watch, you should assume that you are the official spokesman for EPA on pesticide
 issues and that you will be interviewed by the person who put together this newscast.

 The Mock Interview

       After the clip is over, you will split up into small groups. In your groups you will
 prepare both questions and answers for an  interview between  the reporter who put together
 that piece and the EPA chief of the Special Review Branch.  When we get back together, each
 group will ask questions of the others.

       Consider that this broadcast aired in December 1983, so that the Agency has moved
 to suspend the use of the chemical on soil but has yet to act on its use as a grain fumigant.
 Keep the following list of items in mind in order to assist in your preparation for the interview:

    •  What will be your objectives in the interview?

    •  What is your strategy for achieving these objectives?

    •  What facts are critical?

    •  Who is  your audience?

  .  •  What message(s) do you want to convey?

    •  How will you evaluate how well you have done?

       Be sure to identify what you want to accomplish during the interview.  Think of 2-3 key
points and be sure to emphasize them whenever appropriate.
RISK Communication Workshop                                   Dealing with the Media- 6

              Discussion Questions - EDB Role Play
       The potential interview questions noted below should help you get started in
preparing for the interview.
   1. How can you justify allowing the continued use of this material when it can have the
      drastic effects that we saw in the video clip?
   2. What other problem chemicals haven't you told us about?
   3.  Were you protecting the public when you failed to announce publicly that you found
      this chemical in flour destined for the school lunch program? Why didn't you warn
      parents so that they could tell their children something very simple - like don't eat the
   4.  How much EDB is safe?
Risk Communication Workshop                                   Dealing with the Media- 7

    EDB  Background

    •  Ethylene DiBromide (EDB) is now classified as a B2 probable human
       carcinogen.  It is an insecticide and fungicide that was used as a fumigant in
       soils, on grain and on citrus from the mid 1950's through 1984. It was an
       effective and widely used chemical on much of the nations grain.  The silos it
       was  stored in were also treated with EDB.

    •  No,tolerance was set  for EDB since when it was first registered it was
       presumed that there was no residue left on the fruit or grain by EDB

    •  In the late 1970's, the EPA was aware that residues of EDB was being found on
       grain products and the chemical was also being found in ground-water systems

    •  On 9/30/83, EPA announced an emergency suspension of soil uses of EDB,
       thereby halting approximately 90% of the use of EDB nationwide

    •  In October, 1983, the Agency prepared a cancellation order for use of the
       chemical  on  citrus,  but it was appealed  by  users

    •  In December 1983, Florida, after finding residues of EDB in grain products in
       supermarkets, set a statewide tolerance  of one part per billion (1 ppb) and
       started removing products with levels above the tolerance from the shelves

    •  A  number of other  states also set limits:

           Massachusetts  (10  ppb)      California  (300 ppb)

    •  In late 1983, EPA was not convinced that the data supported a cancellation of
       the use of the chemical on grain, although the agency had cancelled the soil use
       to  eliminate ground water contamination.

    •  In  late 1983, the Agency requested information from the states and other
       sources with regard to the establishment of a tolerance level for EDB. The
       Agency could only issue a guidance because of an exemption from tolerance
       that had been given EDB in 1956  when it was  believed that the pesticide left
       no residue.

    •   In  February,  1984, Administrator Ruckelshaus  announced a ban on all use of
       EDB on grain and that a decision on citrus would be forthcoming. With regard
       to treated grain he established three different guidance  levels:

          for raw grain (900 ppb)                                                                   ;

          for uncooked products (150 ppb)

          for ready to eat products (30 ppb)
Risk Communication Workshop                                    Dealing with the Media- 8

   What to do when you disagree with the Agency position

      Now let's look at a different question. How do you believe that one should respond
when he/she disagrees with the Agency position they have to defend?

      In "Improving Dialogue with Communities":  A Short Guide for Government Risk
Communication", (See Resource Document, page 34) Caron Chess, Billie Jo Hance and Peter
Sandman note that:  "If your personal position does not agree with agency policy, do not
mislead the community. Instead, try modifying the agency position or having the task
reassigned.  Or find a way of acknowledging the lack of consensus within the agency.
Misrepresenting the situation or dodging questions about you position will obviously reduce
your and the agency's credibility."

      Do you agree? Can this be done?
             Video Segment - McNeil-Lehrer Interview
      As you watch the next clip, which shows Paul Lapsley of the pesticides office at EPA
being interviewed on McNeil-Lehrer after the Ruckelshaus press conference, keep the
following in mind:
   •  Did he do a good job? Why?

   •  Was he prepared?

   •  Did he meet the concerns of the public?

      In the attached resource document you have a short piece written by Paul Lapsley
which describes his views on how to prepare for an interview:
RISK Communication workshop                                  Dealing with the Media- 9

          Video Segment - Ruckelshaus Final Word on
          Additional Readings in Resource Section-
          Dealing with the Media/ Handling Tough
     Preparing for the Interview by Paul Lapsley. p. 61.
     Presentation bv Tom Vacor on the Role of the Media in Risk Communication.
     p. 63
     Do's and Don'ts for Spokesperson, p. 67
Risk Communication Workshop
Dealing with the Media-10




       One of the more important problems facing the risk communicator is trying to explain
highly technical problems to the public. This is still what many people think defines risk
communication - can you tell me how to explain 1 in a million better or how to explain a risk  .
estimate of 4 per million! This is obviously very important - you have to be able to give
people information they need in a way they can use. However, as we have seen, it is not all
there is to risk communication. The goal of risk communication is to provide the
individuals with information in a manner that is meaningful to them!

       When  explaining technical matters to the public, it is very important that you fashion
the presentation to ensure that it meets the needs of your audience, and not just your needs.

Uncertainty and Timing
       Associated with the issue of explaining technical issues are two related issues -
deciding how to address scientific uncertainties when communicating scientific results to the
public and deciding when to release information to the public.

       As discussed earlier, the risk assessment process yields uncertain results.  The use
of animal  data, the models used to estimate dose-response and exposure figures, all raise
questions  about how "hard" the results are.  Uncertainties and questions about data and
conclusions reached about them characterize almost all risk decision-making efforts.

       At  a Risk Communication Conference in 1986, Frank Press of the National Academy
of Sciences discussed the ubiquitous nature of uncertainty in science, saying "It is important
to understand that uncertainties are not unique to matters of risk.  They are really what
drives all of science. If there were certainty, there would be no science."

       As a communicator, you have to acknowledge these uncertainties and explain what
you are doing to try to limit them.  Recognize that others will reach different conclusions,
looking at  the same information, and the public will often be receiving conflicting views of the
same information.

       Think, for example, of the situation the Agency faced with regard to alar, a chemical
used on apples. Environmental groups were using the same data as EPA, but reaching
different conclusions.

       You must be willing (and able) to discuss the procedures used to develop information,
where uncertainties lie in the process and the efforts underway to resolve them. The Agency
does not have the only answer to a problem, but you have to have a defensible one.  You
should be  prepared to discuss how you've reached your conclusions, the differing conclusions
that others have reached, and you think yours is right.
Risk Communication Workshop                                Explaining Technical Issues -1

       Remember - There will always be uncertainty. As one county official told researchers
 from Rutgers University "Environmental epidemiology makes economics look like an exact
 science....and what we do know is very technical."

       One of the easiest ways to lose trust and credibility with an audience is to withhold,
 or be perceived as withholding information.  Remember the EDB tape, one of the strongest
 indictments made about EPA was the implication that the Agency knew about problems but
 wasn't acting on them, or informing others. Whether it is true or not, being perceived as
 withholding information is obviously very damaging to your credibility.

       If you want people involved in the process (no matter where they are on the Ladder of
 Citizen Participation) then you have to give them information in a timely manner, in a way
 that is meaningful to them. You want to get the best information out to the public as quickly
 as possible. Decisions on when to release information, how to do so, and who should receive
 it, should all be part of a risk communication plan.  We will discuss the importance of these
 plans, and what they should include, in the next chapter.

       There will obviously be circumstances when you  can't release information, whether for
 legal reasons or concerns you have about its  accuracy.  Note there is a difference between
 recognizing uncertainties about your data and questioning the data's accuracy.  Release what
 you can and let people know why you can't provide other data and when you might be able to.
 Keeping the public informed will enhance their feeling of control and, as we discussed earlier,
 lower the "outrage" they may be feeling.

       Please refer to page 141 in the Resource Document for a list of Ten Reasons to
 Release Information Early, developed at Rutgers.
              Discussion  Questions  -  Explaining Technical
   1.  How do you justify making decisions about which you have doubts?
      How can you explain that the risk estimates the Agency assigns to various chemicals
      or to an overall site (as in Superfund) generally exaggerate the potential risk.  How
      does this over estimate of the potential risk affect policy?
Risk Communication Workshop
Explaining Technical Issues -2

   3.  What are some general guidelines that should be used in communicating technical
       matters to. the public? What advice would you give to a colleague about preparing a
       presentation for an intelligent, but not scientific public.  After we develop a list
       together in class, you'll receive a  handout on general guidelines to follow in
       presently technical information.
                isk Comparisons
       One of the most successful ways to communicate about technical issues is by using
comparisons. A well throughout effective comparison can help put the particular situation into
perspective for individuals.  These are, however, pretty rare and the inappropriate use of
comparisons can have disastrous results for your credibility and for your communication

Guidelines  for Risk Comparisons

       The Chemical Manufacturer's Association has assembled a manual on risk
communication for its plant managers entitled Risk Communication. Risk Statistics and Risk
Comparisons:  A Manual for Plant Managers. Its authors, Vincent Covello, Peter Sandman
and Paul Slovic developed an analysis of appropriate comparisons based on their relative
acceptability.  As well as addressing other risk communication issues, the manual goes into a
great deal of detail  on the appropriate and inappropriate use of risk comparisons.  Some of the
key points made in that document are noted below:

   •   No risk comparison will be successful if it appears to be trying to settle the
       acceptability question since "acceptability" is a  value question, not a technical
       one. Your job is to help the public reach its own decision on the
       "acceptability" of the situation.  You can try to help  put data into perspective -
       it is then up to the  recipient to decide how he/she wants to use that

   •   Quantity comparisons are more useful than probability comparisons.

   •   Use comparisons of the same risk at different times (i.e. before and after the
       controls were put on)

   •   Use comparisons with a standard (i.e., vs. 10"")

   *   Compare with different estimates of the same risk: that of the
       environmentalists and industry and your own. If some one else has a higher
       risk estimate - say  so!
Risk Communication Workshop
Explaining Technical Issues -3

    •  Compare the risks associated with your proposed solution or action to that of
      . alternative solutions.

       In general, it is important that you carefully think through any comparison that you
 want to use.  There are no absolute rules or guarantees about what is or is not an effective
 comparison.  You must be as diligent in discerning the appropriateness and accuracy of a
 proposed comparison as in providing any sort of technical information. Be especially
 cognizant of your audience and their concerns and only use a comparison that addresses
 those concerns adequately!
       Two articles in the resource document (pp. 97 and 111) discuss the appropriateness of
 using comparisons between unrelated risks.  As you review the articles, ask yourself if you
 think there are there instances when these comparisons would be appropriate?

       In trying to determine the appropriateness of a comparison, try to see it through the
 perspective your audience. Will this help them better understand the situation at hand?
 Remember, that should be the goal of the comparison - to help your audience understand.

       Be careful: An inappropriate comparison, which the audience finds "off the wall" or
 patronizing or otherwise wrong can turn the audience off so they will not hear your message.
              Discussion Questions - Risk Comparison
   1.  What makes a comparison work for you?
   2.  What effective examples do you have of comparison? Ineffective?
Risk Communication Workshop
Explaining Technical Issues -4

              Video Segment  • ICE Minus
      The next segment of tape shows small portions of a press conference at which Jack
Moore, AA for Pesticides and Toxic Substances at the time, is discussing the Agency's
decision to permit on-field testing of a genetically altered bacteria (ICE minus) that will
inhibit the freezing of strawberries.  The clip also includes some discussion by one of the
primary scientists involved in the experiment.  In addition, Steven Lindow, the lead scientist
on the ICE Minus experiment is seen explaining the nature of the experiment to the public, in
a number of different fora.

      Consider the following questions when viewing the tapes:

      What did  you think of Mr. Moore's presentation,  especially with regard to the 7
      Cardinal Rules?
      What is your reaction to Mr. Lindow's assertion that "no deliberate introduction" of a
      species has led to problems?  Do you agree? Did you find the statement helpful or
      Did you like his "comparison of the genetic change to the bacteria to removing one
      piano key? What about his graphics?
      What is your reaction to his statement that you should have faith in the scientists?
Risk Communication Workshop                                Explaining Technical Issues -5

             Video Segment - State of California

      In this next tape, a California doctor, Lynn Goldman, is shown talking to a group of
 individuals at a meeting concerning contamination of drinking water.  As you watch, consider
 whether she is an effective speaker.  Why or why not? How does she do with regard to the
 seven cardinal rules? with regard to  the list we've developed as guidelines for explaining
 technical risks?
             Additional Readings in Resource Section -
             Explaining Technical Issues
   •  What Do We Know about Making Risk Comparisons . p. 71

   *  What Should We Know About Making Risk Comparison, p. 85

   •  Explaining Environmental Risk: Some Notes on Environmental Risk, p. 89

   •  Typical Questions and Sample Responses, p. 119

   *  Ten Reasons to Release Information Earlv. P-
Risk Communication Workshop
Explaining Technical Issues -6




Why do you need a risk communications plan?

       In order to provide the public with the opportunity to participate meaningfully in
agency decision-making, the public must be involved early in the process (see
Cardinal Rule #1).  This will not happen on its own, but the agency must plan for and
actively seek this participation.

       It is important to recognize that an effective communication program is an
analytical one, requiring the identification of goals and objectives, activities to reach
those goals, ways to evaluate the degree to which the goals have been met, and
mechanisms to allow for changes resulting from the evaluations. As we saw in the
MARJOL case, communications cannot be simply left to  the last minute.  Rather, the
agency must recognize that the communications strategy  is critical to the success of
the risk management process.  In the absence of effective planning and preparation,
communications fiascoes such as the MARJOL meeting can undermine all the good
work that the agency is doing at a site or in developing a  rule.

       The need for effective communication planning has broader implications than
the preparation for  and assessment of a particular communication event such as a
public meeting or a media interview.  That is certainly important, but we are referring
to a view of communication planning that is part of the whole decision-making process,
that enhances effectiveness of events (like a public meeting) that occur but that also
helps  the Agency, other government entities, including the public, and other interested
parties work together to reach the best possible management decision.

       In its brochure on the Seven Cardinal rules for Risk Communication, EPA offers
the following guidelines to meet the 2nd Rule; to Plan Carefully and Evaluate Your
  . -     •                        i
       Begin with clear, explicit risk communication  objectives - such  as providing
information to the public, motivating individuals to act, stimulating response to
emergencies, or contributing to the resolution of conflict.  Evaluate the information you
have about the risks and know its strengths and weaknesses.  Classify and segment
the various  groups in your audience. Aim you communications at specific subgroups in
your audience. Recruit spokespeople  who are good at presentation and interaction.
Train your staff - including technical staff - in communication skills; reward
outstanding performance.  Whenever possible, pretest you messages.  Carefully
evaluate your efforts and learn from your mistakes?
Risk Communication Workshop                           Planning for Risk Communication-1

       Points to consider:

   1.  There is no such entity as "the public"; instead, there are many publics, each
       with its own interest, needs, concerns, priorities, preferences, and
       organizations. .

   2.  Different risk communication goals, audiences, and media require different risk
       communication strategies.

What constitutes an effective plan?

       The following list will serve as the starting point for group discussion on
developing a communications strategy. It comes from work done at Rutgers
University and discussed in Planning Dialogue with Communities: A Communication
Workbook, which is included in its entirety in the resource section, on page  159,
Determine your goals - depending on the situation

       Be clear on what you hope to accomplish?

       Identify your audiences and their specific concerns

       It is important to identify all those who may be interested in your activity or
       who can provide you with information: set priorities among the groups,
       establishing a core group that will be directly involved and others that will not
       be so directly involved.

       Design your message to meet those concerns

       Think of satisfying  the audiences needs - not yours.

       Choose the best methods to reach people

       For some groups, informal meetings are best. Be sure you know how you
       intend to reach people. What are the biggest roadblocks?

       In order to ensure you reach people who might not usually be involved, you
       should cast as wide a net as  possible.  This is important to ensure equity.

       Other agencies do this first, before they've identified the audience.

       Coordinate internally

       Practice the same r.c. principles on others in your agency as with the public.
Risk Communication Workshop
Planning for Risk Communication- 2

      Plan for evaluation

      How to build in procedures to evaluate how you're doing and make changes
based on the results of the evaluation.
             Discussion Questions  * Planning for Risk

      Suppose it is November 1988 and you, the Branch Chief of the Special Review                 I
      Branch, suspect that something might be stirring in the wind concerning Alar, a                I
      pesticide used on apples.  How would you develop a strategy to both find out
      what others are thinking and to communicate the agency's position with regard
      to Alar? Who  should be involved in this strategy development? What would
      be the main components of the plan with regard to the items noted above?
   2.  What would be the major roadblocks to development and implementation of the
      strategy? How might you get around them?
   3.  How could you use TQM principles in developing the plan?
      As we have pointed out, evaluating how your communications plan is going and
      making changes in your plan to help meet its goals and objectives is an integral
      component in a risk communication strategy.

      This type of evaluation, identifying the degree to which the communication
      actives are successful in reaching goals and objectives, is referred to as an
      outcome evaluation. Evaluation techniques can also be used in the beginning
      stages or a plan development, to pre-test materials to see if they are

Risk Communication Workshop                           Planning for Risk Communication- 3

       appropriate for the targeted audience, and during the implementation of the plan
       to see how the planned activities are proceeding.  These types of evaluations
       are referred to as formative and process respectively.

       The type of evaluation used at any given stage in the plan development and
       implementation will depend to a great extent on the time and resources
       available. For example, in the pre-test or formulative stage, techniques can
       range from readability tests that evaluate die clarity of a particular article to
       the use of focus groups, that can be used both to test the applicability of
       materials and presentations and to learn more  about evidence perceptions,
       beliefs, and needs. The formative evaluation should help determine clarity,
       comprehensibly and comprehensiveness for the materials to be used.

       The table on the following page, adopted from "A Guide to Practical
       Evaluations," an EPA document prepared by Michael J. Regan and Williams
       Desvousges of the Research Triangle Institute, shows some of the techniques
       that can be used for formative, preview, or outcome evaluations.

       For more information on all these types of evaluation, the reader should see
"A Guide to Practical Evaluations", an EPA document prepared by Michael J. Regan
and William H. Desvousges of Research Triangle Institute  and also, in  the Resource
Document, "Evaluating Risk Communication Programs,"  by Mark Kline, Caron Chess
and Peter Sandman.
             Discussion Questions - Planning for Risk
   1.  What evaluation tools have you used in your work? Which have been most
   2.  What limits your ability to do more evaluation?
Risk Communication Workshop
Planning for Risk Communication- 4

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            Additional Readings in Resource Section
            Planning for Risk Communication
   •  Focus Group Techniques, p. 143
   •  EPA Title III Focus Group Results, p. 145
   •  "Focus-Groups and Risk Communication: The Science of Listening to
      Data." p. 153
   •  Planning Dialogue with Communities: A Communication Workbook.
      p. 159
   •  "Evaluating Risk Communication Programs." p. 203
Risk Communication Workshop
Planning for Risk Communication- 6



      It is July 1983 and the EPA has just issued a proposed rule (including
alternative approaches) for regulating the emissions of arsenic from the AS ARCO
copper smelter located in your region.  Even though a specific approach is presented in
the rule, the Administrator has made it clear in no uncertain terms that he wishes the
final rule to take into account the public's desires.  While the final decision will be his,
he is more than willing to change the proposed rule based on public comments.
      Much of the key information about the ASARCO copper smelter and the
proposed regulation is included in the attached case study and appendices.
      In reading the attached material we ask that you keep a few basic questions in
   1.  What constitutes "the public"?  What public is the Agency trying to
   2.  What are the key facts from the public's perspective and from the
      EPA's perspective?
   3.  Why is EPA involving the public and what is EPA's objective?
   4,  What strategies should the Agency follow to achieve those objectives?
   5.  What particular messages is EPA trying to convey to specific
      individuals and how will you present them?
   6.  What is the specific program for involving the public?
   7.  How should EPA evaluate its efforts?
             Development of a Communication Strategy
      After the review of the case material, we will use the facts presented in the
case to develop a communications strategy.
             Role Play
      Later in the course, we will conduct a mock public meeting during which time
EPA will present the background of the proposed rule to the public and learn first hand
of the public's concerns. The following material will provide the background
information for the role play.
Risk Communication Workshop                                           Case Study • 1

              The Smelter
       The ASARCO/Tacoma copper smelter is located in Ruston, Washington (see
Figure 1). The facility is situated in an industrial area adjacent to Tacoma and
bordered to the north by Puget Sound. Across Puget Sound, downwind from the
smelter site, lies Vashon Island, a more rural, middle to upper-class neighborhood
where many vocal citizens opposed to the smelter reside. The Tacoma/Ruston area, a
more urban and blue-collar area, is where many of the smelter employees and other
concerned citizens live.

       The ASARCO/Tacoma facility is the only U.S. smelter to process ore with a
high arsenic content. Built in 1890 as a lead smelter, the facility was bought by
ASARCO in 1905 and was converted to a copper smelter in 1912.  Since the
conversion of the facility, the smelter has operated as a custom smelting operation,
utilizing copper feed ores with an average arsenic concentration of 4%, much higher
than the typical 0.6% arsenic concentration for ore used at other U.S. copper smelters.
For this reason, the facility is able to produce commercial arsenic as a by-product of its
smelting operation. The ASARCO/Tacoma facility is the only U.S. producer of arsenic,
accounting for one third of all the arsenic used in the United States. The facility,
however, is also responsible for approximately 23% of the total national inorganic
arsenic emissions, and is the only such source of airborne arsenic in the area.
              Arsenic Emissions
      Arsenic emissions occur at several points during the production of copper.
Fugitive, or ground-level emissions occur during the transfer of copper ore between
the major steps of production.  Of primary concern are the "fugitive" emissions of
arsenic that occur when the molten ore mixture is  sent from the furnace to conveners.
Gases collected from the furnaces and the hoods enter the pollution control system,
and arsenic, SO2, and participates are removed partially by means of a flue gas
cleaning system, these pollutants, however, are still present in tall stack emissions
after going through the flue gas cleaning system.  The greatest risk is from the .
fugitive emissions because they are emitted at a relatively low altitude and are not
dispersed easily to the environment.
Risk Communication Workshop
Case Study - 2

                             FIGURE 1
Risk Communication Workshop
Case Study - 3

             Pollution Control Investments
      For the past fifteen years, the facility has been involved in numerous legal
battles with the Puget Sound Air Pollution Control Agency (PSAPCA) over SQ2,
particulate, and arsenic controls (the PSAPCA had been delegated authority from the
state).  These disputes began in 1968, when PSAPCA adopted enforceable ambient
and stack concentration standards for SO2-  From 1968 to the present, ASARCO has
implemented several environmental controls, yet all the while has petitioned for
variances and extensions on meeting the standards.

      In 1981, PSAPCA required ASARCO to install secondary hooding on the
smelter converters. This requirement was associated primarily with SO2 and
paniculate controls, although the installation of hoods would also greatly reduce
fugitive arsenic emissions. The conveners, where the sulfur is burned out of the
molten copper mixture, account for a large proportion of the fugitive emissions of
gases.  Primary hoods capture most gases released, but secondary conveners that
would cover the primary hoods would catch additional emissions. These secondary
hoods would play  a particularly important role when the conveners were rotated to
receive and dispense the molten copper, at which point the primary hoods are less
effective. While ASARCO installed one secondary hood, the company has delayed
the installation of additional hoods.
   * $
ASARCO's Economic Position
      As EPA develops a proposed standard for arsenic, questions have arisen as to
the strength of the ASARCO/Tacoma facility's financial position. According to a 1981
assessment by Roben Coughlin (an EPA Region X Economist), the Tacoma facility
has a limited economic life, probably of less than five years.  This is due primarily to
overcapacity within the copper industry and overcapacity within ASARCO itself. A
number of copper smelters have opened overseas, including one that utilizes high-
arsenic feed ore.  This has led to a decrease in the availability and a resultant increase
in price for the imported high-arsenic feed ore. The increased world-wide competition
contributes to the reasons why several ASARCO facilities in the U.S., including the
Tacoma facility, are operating far below capacity.  Along with this overcapacity within
the industry and the increasing price of high arsenic feed ore, another major factor
affecting the fate of the Tacoma facility has been the increasing cost of environmental
Risk Communication Workshop
                                                       Case Study - 4

       In Tacoma, the smelter plays an important economic role.

       The ASARCO smelter employs approximately 600 people and
       contributes $20 million in goods and services and $2 million in taxes to
       the area.

       An additional 500 jobs in the area are indirectly related to the smelter
       operation.  Plant closure would therefore have a significant impact on
       the community.
              Arsenic Regulatory  Status
                                                                   *       •

       Arsenic was designated as a Hazardous Air Pollutant (HAP) under Section
112 of the Clean Air Act (CAA) in 1980. The National Cancer Institute and the
National Academy of Sciences classify arsenic as a carcinogen based on a statistically
significant link between high occupational arsenic exposures and skin and lung cancer.
In addition, inorganic arsenic is well known as an acute poison to humans in high

       In response to a suit from the state of New Jersey objecting to arsenic
emissions from a New York glass manufacturing plant, a United States District Court
in New York directed EPA to propose a national arsenic standard.  As part of this
effort, EPA was directed to promulgate a separate standard for the ASARCO/Tacoma
facility, the only copper smelter to process high-arsenic ore and the largest single
source of arsenic emissions in the U.S.

     '  According to the language of the Clean  Air Act, standards for hazardous air
pollutants such as arsenic must be based on an "ample margin of safety". For
carcinogens, however, an "ample margin of safety" appears paradoxical.  As we
discussed earlier,  EPA's approach assumes most carcinogens demonstrate  a dose-
response relationship at all doses.  In other words, any exposure to arsenic may
increase the likelihood of cancer, with the risk  increasing as exposure increases.  To
reduce arsenic emissions to a zero level, therefore, would require the closure of all

       EPA therefore has taken the approach of implementing the requirements of the
Clean Air Act by  controlling emission sources  to the level that reflects the Best
Available Technology (BAT). The selection of BAT is based on an assessment of the
best controls available, considering the economic, energy, and environmental impacts.
EPA will then decide if further controls  are necessary due to unreasonable residual
health risks. This approach has been embraced by William Ruckelshaus, EPA
Administrator. However, EPA can impose  standards that go beyond BAT if, in the
language of the statute, it is necessary to "protect the public health...with an ample
margin of safety."
Risk Communication Workshop                                             Case Study * 5

       In the .case of the ASARCO/Tacoma smelter, the potential impacts of EPA's
proposed standard are great.

    •   Stringent emission requirements would have high compliance costs and
       could force the plant to close, thereby cutting off a major employer and
       revenue source for the community.

    •   With moderate controls, the remaining health risks posed by the
       smelter are higher than risks associated with other regulated hazardous
       air pollutants.

       For this reason, EPA is trying to gather public input to assist in the
determination of whether BAT controls are acceptable, or whether more stringent
controls are necessary due to potentially unreasonable residual health risks. EPA has
decided to consider the costs of the various alternatives and to assess the health
effects and risks to the maximum exposed individual (MEI) and the entire exposed
population.               ,      •

    Related  Superfund Activities

       While EPA has been developing a proposed standard, EPA has also been
conducting studies related to arsenic and cadmium concentrations in the soil,
sediment, and sand of the area and arsenic in the urine of school children. Last April,
the Washington Department of Ecology (DOE) and EPA agreed to an investigation of
contamination in the area designated as the Commencement Bay Nearshore Tideflats
Superfund Site. Parts of Ruston, Tacoma, and Vashon Island, along with the adjacent
bay areas, are included in this site designation. Soils in Ruston and Vashon Island
are known to contain arsenic and cadmium in amounts great enough to warrant
concern about eating vegetables from contaminated soil.

       Following its designation as a Superfund site, the DOE planned investigations
to identify sources of arsenic and cadmium contamination.  Once the sources and
problems are identified, remedial measures will be conducted.  One investigative task
is clearly related to the ASARCO smelter.  The DOE, along with the Tacoma-Pierce
County Health Department, is trying to determine the exposure pathways by which
arsenic is appearing in the urine of children who live close to the smelter. This
investigation will address the possible exposure through inhalation of arsenic in the
air due to emissions and resuspended dust as will  as possible exposure through
ingestion of contaminated vegetables, drinking water, and soil.  Cadmium
contamination is also being investigated.

       Other Superfund investigations focus on the extent and risk of contamination of
aquatic life and sediment in the water.  An analysis of seafood is also anticipated as
part of this inquiry. EPA is keeping the ASARCO smelter proposed regulations
separate from the Superfund activities.
Risk Communication Workshop
Case Study - 6

EPA Proposed Arsenic Standard

      In its proposed rule EPA employed a three-step approach to determine the
control requirements being proposed.

   1.  A determination whether BAT is in place for all emission points

   2.  Selection of BAT for emission points identified as needing standards

   3.  Investigation  of alternatives

      The recommended standard would require Best Available Technology (BAT)
on converter fugitive emissions. All other emission sources at ASARCO are believed
to be controlled to the level of BAT. The installation of two additional secondary
hoods would fulfill the BAT requirements for converter fugitive emissions.

      The proposal includes the following language which specifies the Agency's
interest in public involvement in the standard setting process:

      "As now written, this proposed  regulation would leave some of the residents
of Tacoma exposed to a relatively high estimated risk of lung cancer when compared to
the risk around other sources of arsenic. The Administrator is especially eager to hear
comments from the residents of Tacoma on whether this remaining degree of risk is
appropriate and how this decision should be made."
                       EPA Risk Calculations
      EPA's calculation of the human health risk of developing lung cancer from
arsenic exposure provides the basis for the draft of the proposed standard for the
ASARCO/Tacoma facility.  The proposed rule focuses only on cancer risks to the
population from air emissions of arsenic.  Other health risks and ecological risks are
not specifically addressed. In part, these risks are excluded because EPA is in the
process of addressing them through Superfund activities.  The ASARCO site was
included in the area designated as the Commencement Bay Nearshore/Tideflats
Superfund Site in April  1983. Superfund studies and risk assessments are currently
underway to examine the risks associated with arsenic and cadmium already present
in the soil.
Risk Communication Workshop                                           Case Study - 7

       In conducting the risk assessment, EPA evaluates the hazard associated with
arsenic, evaluates the health risks resulting from different levels of arsenic as
described through dose-response estimates (the unit cancer risk factor), and
estimates population exposure levels.  EPA then characterizes the risk and the cost of
controls, and alternatives to the proposed controls.  Each of  these steps is discussed
in the following sections.

       Brief descriptions of the results of some studies based on Tacotna data that
provide more information to the risk assessment follow:

    •   Enterline and Marsh observed a cohort of 2802 workers at the
       ASARCO smelter from 1940 to 1964. Their study did not statistically
       confirm a dose-response relationship, except when all retired  workers
       were included in the data set.

    •   A 1978 study of lung cancer mortality, conducted by the Fred
       Hutchinson Cancer Research Center, failed to document excess cancers
       within the Tacoma population associated with arsenic  exposure from
       the smelter.

    •   A 1977 cohort study by Pinto et al. reflected a dose-response
       relationship as shown through urinary arsenic  levels.  This dose
       response relationship was also dependent on  the duration and intensity
       of arsenic exposure.

    •   In the 1970s, the DSHS confirmed the presence of arsenic in the urine
       and hair of children living near the smelter.  The concentration of arsenic
       declined with distance from residences to the  smelter.  Samuel Milham,
       of the DSHS, indicated  that although high levels of arsenic existed in
       the soil and in children's urine and hair,  there  was no evidence of any
       adverse health effects associated with the presence of arsenic.

    •   The Puget Sound Air Pollution  Control Agency indicated that the
       average urinary arsenic levels in  Ruston and Vashon (reported at 36
       and 23 micrograms/liter, respectively) were significantly higher than a
       control group in Olympia (with a reported level of 12 micrograms/liter).
                        Hazard Identification
       Evidence from occupational exposure data from smelter workers indicates that
a direct link exists between high arsenic exposures and lung cancer. The risks were
shown to increase with an increase in cumulative arsenic exposures.  However, the
Risk Communication Workshop
Case Study - 8

carcinogenicity of arsenic in humans is not well understood.  While these studies
confirmed to the scientific community that arsenic is a human carcinogen at lower
doses, animal tests, however, have not confirmed the results of occupational
analyses.  In fact, some animals appear to have a dietary need for arsenic although
this need has not been demonstrated in humans.

       Other noncarcinogenic health effects have also been documented including
nerve damage, hemoglobin synthesis impairments, and hearing loss in children.
              Dose-Response Evaluation

       The dose-response relationship for arsenic was identified using data from the
studies of lung cancer incidence in workers exposed to high levels of arsenic.  These
effects found at the higher occupational exposures are mathematically extrapolated to
lower concentration levels. These lower concentrations more nearly reflect the
exposure of people around the AS ARCO smelter.

       Using a linear extrapolation, EPA calculates the expected (modelled)  response
at doses lower than the occupational levels.  This linear extrapolation represents a
"conservative" estimate of the probability of developing cancer from inhalation at low
doses in that the actual risk is unlikely (95% confidence) to exceed the risk estimated
using the linear extrapolation.
               Exposure Evaluation
       Total exposure is determined by dispersion modelling estimates of the arsenic
concentration in the ambient air surrounding the smelter combined with data for the
distribution of the 370,000 people living within 121/2 miles of the smelter.

       Emissions:  Fugitive source emissions are too difficult to measure and
therefore are estimated.  The stack emission rate used in the analysis, however, is
derived from emission tests.

       Dispersion: EPA uses a model to calculate the dispersion  of arsenic emissions
within a 121/2 mile radius of the facility. The complex geography of the area and
imprecise meteorologic data make dispersion calculations difficult.  Because of these
difficulties, and EPA's relatively high calculation of emission rates, the modelled
results of ambient concentrations are higher  than the actual measurements of arsenic

Risk Communication Workshop                                            Case Study-9

      Population Location:  Census data estimates of population location within the
12 1/2 mile radius are combined with the modeled ambient concentrations of arsenic to
determine the population exposure.

      Exposure -Duration:  The estimated exposure level assumes that individuals
are exposed to a constant average concentration of arsenic for 24 hours per day for a
lifetime of 70 years. For  workers at the smelter, this average concentration exposure
represents an underestimate of exposure levels, yet for residents spending time
outside of the Tacoma area, this exposure level represents an overestimate. This
estimate of exposure is based solely on inhalation of arsenic emitted by the smelter
through stack and fugitive emissions.

      According to EPA estimates, the proposed  standard, requiring the installation
of additional secondary hoods, will significantly reduce arsenic emissions. EPA's
estimates, however, are significantly different from ASARCO and PSAPCA

      EPA estimates that fugitive arsenic emissions will be reduced from  134
      million grams (Mg) per year to 24 Mg per year. (Total emissions will
      thereby be reduced from 282 Mg to 172 Mg.)

      ASARCO's estimates of emissions, prior to the installation of controls,
      are much lower (Table 1).  ASARCO calculates that total emissions,
      without secondary  hoods, are closer to S3 Mg (59 tons).

      PSAPCA calculations indicate that total emissions are 93 Mg before

      Ambient monitoring data around the facility provide some additional indication
of the concentration of arsenic in the  air. These data, however, are limited in quantity
and also show major differences,

      ASARCO's monitoring stations in Ruston indicate that the
      concentration of arsenic in the air is approximately 0.2 to 0.9
      micrograms per cubic meter.  (The OSHA standard for arsenic
      concentrations is 10 micrograms per liter.)

      According to a newspaper account of ASARCO's description of the
      data, EPA calculates that the level of arsenic in the air near the smelter
      is approximately 10 to 30 micrograms per cubic meter.

      This difference between the ambient data and modelled data may be
attributable to the fact that EPA's model uses input based on assumptions about
emissions and dispersion,  and cannot precisely predict the effects of complex
geography and meteorology.  In addition, the location of ASARCO's monitoring
stations is uncertain; they may be located at more  distant points.
Risk Communication Workshop
Case Study -10

       Although EPA uses estimates of ambient concentrations ranging up to 30
micrograms per cubic meter, this highest value is used only to calculate the risk to the
maximum exposed individual. In EPA's exposure model, concentration levels at
which the majority of the population is exposed are less than 0.05 micrograms per
cubic meter.



Current Emissions

(million grams)
EPA's Estimate:
ASARCO's Estimate:
PSAPCA's Estimate-






Emissions After
(million grams)
EpA's Estimate:
ASARCO's Estimate:
Not applicable
(none made)

PSAPCA's Estimate:
Not applicable
(none made)



Risk Communication Workshop
Case Study-11

                       Risk Characterization
      Annual cancer incidence associated with arsenic emissions from the ASARCO
smelter is the product of the total population exposure around the smelter and the unit
risk number, calculated as divided by 70 years. Based on EPA's modelling of
emissions and resultant exposure estimates, and an estimate for the unit risk factor
for arsenic, the health effects at levels proceeding and following installation of controls
are calculated.

      The maximum lifetime risk represents the probability of a person contracting
cancer who has been continuously exposed during a 70 year period to the maximum
(30 ^ig/m3) arsenic concentrations from the smelter. The average lifetime population
risk represents this probability for an individual who has been continuously exposed to
an arsenic concentration of approximately .5

Total Inorganic arsenic
Average lifetime cancer risk*
Maximum lifetime cancer
risk" (for the Maximally
Exposed Individual - MEI)
Lung cancer incidence within
12 1/2 miles of the facility
311 tons/year
2 X 10"4
A range of 2.7 - 37 per 100
with a best estimate of 9/100
1.1 -17.6/yearwith a best
estimate of 4/year
189 tons/year
4 X 10"5
58 - 9.2 per 100 with a best
estimate of 2 per 100
0.2 - 3.4/year with a best
estimate of 1 per year
Annual background lung cancer rate in the Tacoma area is 71 - 94
*The mean concentration of arsenic in the air is calculated as 0.5 ug/m3
"The maximum concentration of arsenic in the air is calculated as 30 ug/m3
Risk Communication Workshop
Case Study -12

      EPA estimates the economic costs of such control measures to be the

   •  $3.5 million in capital costs.

   •  $1.5 million in annual operating costs based on increased energy use.

      These costs are based on economic information provided by ASARCO.
Assuming that ASARCO could pass off all  of the additional cost to purchasers, these
costs would translate into an increase in the price of copper of 0.8%.  It is estimated
that the proposed standards will not adversely affect the economic viability of the
smelter or employment at the smelter.


      As noted, EPA can do more than BAT. There are several other alternatives
currently being considered by EPA:

   •  Baghouse controls, (a method of catching paniculate matter within the
      emission  control system, before its release from the stack) are
      considered to be expensive to install and ineffective against fugitive

   •  The use of ore with lower arsenic concentrations has also been
      considered, although this too would be costly for the company. EPA
      estimates that replacing only 15% of the total feed ore with low-arsenic
      material would result in a $2.8 million reduction in net income for the

   •  Better smelting technology could be more effective but would require a
      great capital  investment by ASARCO.

ASARCO  and  Community  Attitudes

      The impacts of an arsenic standard for the AS ARCO/Tacoma facility are of
concern to many individuals and to the community as a whole. Because of the
uncertainty in risk estimates, the economic  impacts, and the potential health effects
associated with the draft of the proposed standard, there will undoubtedly be  a great
deal of debate within the community over EPA's actions.  As would be expected,
there was a wide range of public opinion. This range is reflected in the newspaper
articles included as an attachment.
Risk Communication Workshop                                         Case Study -13

       Among the potential categories into which public opinion might fall are the

   No additional controls will be needed

       A small group of people will probably feel that the facility should continue
operations without installing secondary hoods.  These people will primarily be
employees who feel that they are adequately protected and that no additional controls
will be needed.

   Proposed BAT will provide adequate controls

       A greater number are expected to feel that the proposed BAT controls provide
the proper level of control.  Included in this majority are AS ARCO officials and
managers, as well as a number of residents.  These people believe that there is no
evidence of a health risk associated with the smelter, and any possible health risk is
less important  than the jobs and economic benefits provided by the smelter.
ASARCO employees and some nearby residents have reported in the past that no one
they have known, employees or residents, has developed lung cancer.  They dispute
the existence of a health risk.   Many employees have also expressed in the past that
they feel that there is a threshold level of safety associated with arsenic exposure
below which no adverse effects will be observed.

       ASARCO officials have indicated since the time PSAPCA issued its own
requirement for secondary  hoods, that they are willing to install the proposed hoods
once they receive EPA's assurance that this will represent BAT. They want
assurances that no additional requirements will be placed on the operation. ASARCO
has maintained, however, throughout discussions with PSAPCA, that  there is no
significant health risk associated  with emissions. ASARCO  is certain to assert that
EPA's emission and exposure estimates are too high and overestimate any health

       The  mayor of Tacoma has already indicated that the secondary hoods required
by PSAPCA seem satisfactory and that closure of the plant should be avoided.  "Until
I've been able  to be shown specifically to me that there are indeed deaths being
created by the  emissions out of ASARCO, I don't think it should be closed," said the
mayor. He called ASARCO a "good corporate neighbor", and indicated that it has not
been a source of significant public health risk.

       His view is supported by Dr. Samuel Milham, epidemiologist for the DSHS.
"Unless you can demonstrate you're causing a public health problem, I think it would
be irresponsible to be closing the  plant, and we definitely haven't been able to
demonstrate that."
Risk Communication Workshop
Case Study * 14

   Additional technical controls will be necessary ~

      Others in the community believe that EPA should require secondary hoods but
should also impose additional technically feasible controls. This opinion has been
raised in the past at PSAPCA hearings by a number of local regulatory agencies and
environmental groups, including Fair Share, the Tacoma City Council, and Tahomans
for a Healthy Environment. Many of these people feel both jobs and health can be
protected.  PSAPCA supports this position, and has already indicated that it would
like EPA to go beyond the secondary hood requirements it has already imposed.

   The facility should radically alter or stop operations

      Finally, there are individuals who will probably urge EPA to require the
ASARCO  smelter to use low-arsenic feed ore or stop operation. These people
perceive that a significant health risk will always be associated with the smelter, even
if control measures are taken. Many of these people feel that the Tacoma area would
benefit from the closure of the smelter, perhaps through realizing its goal of becoming
a high-tech center, rather than remaining a home to industrial hazards.
              Developing a  Communication Strategy
      You have been placed in charge of developing a communications strategy for
the region on the proposed smelter rule.  We reviewed earlier the items that
constitute an effective plan and they are briefly noted below. Take the next 15
minutes and fill in following for what you know in the ASARCO case.

   1.  Identify your goals for the risk communication.
   2.  Identify your audiences and their specific concerns. Identify the audience of
      most and lesser importance.
   3. Design your message to meet the concerns of your audiences.
Risk Communication Workshop                                           Case Study -15

   4.  Identify the best methods to reach people.
   5.  Identify the steps necessary for internal coordination.
   6.  Identify your plan for evaluation of the communication strategy.
             Discussion  Questions
   1.  When should you go beyond the communication required by statute?
   2.  What can you do to overcome the "there's not enough time" syndrome that
      often dooms communication with outsiders and within the Agency?
   3.  What steps might be taken to encourage effective communication with outside
      audiences and within the Agency?
Risk Communication Workshop
Case Study -16

              Role Play  - Public Meeting
       An informal public meeting sponsored by EPA, is being held to discuss EPA's
proposed rule. The meeting should be opened by the EPA representatives, who
should do some basic planning using the planning framework identified earlier: decide
what they hope to accomplish at the meeting; establish a format and agenda; prepare
an introductory statement; and so forth. The other participants should prepare their
positions and consider how they want to approach the meeting and what they hope to
achieve.  Note - there is nothing that prohibits participants from talking to one
another to try and workout alliances and strategies prior to the meeting. A listof Jcey
individuals is attached. In the real world special interest groups, whether they be
environmentalists or representatives of the industry, are adept at controlling the
process, and that should be part of the process here.

       In the actual case the EPA held a series of informal public meetings after the
proposed rule was published and prior to finalization. The EPA Administrator was
willing to revise the rule in response to the public's desires if they could clearly be
identified. The participants in this workshop have the opportunity to recreate one of
those meetings.

       The class will be divided into small groups and each group will prepare to both
conduct the meeting (take the role of EPA and the state agencies) and to assume the
role of those attending the meeting (general public, local officials, activists, industry,
etc.).  Each group will be given the opportunity to run the meeting and also to attend

       You should assume the EPA proposed rule has just been published in the
Federal Register and the EPA is holding its first informal public meeting.  The date is
August 30,  1983. The meeting is scheduled to begin at  1:30.

       Good luck... and have some fun!
Risk Communication Workshop                                            Case Study -17








Federal Register / Vol. 48, No. 140 / Wednesday. July 20.1983 / Proposed Rules


 IAH-FRL2J7S-2I --

 National Emission Standards for
 Hazardous Air PoHutanta; proposed
 Standards for Inorganic Arsenic

 AOKMCY: Environmental Protection
 ACTON: Proposed rule snd
 announcement of public hearing. _

 •UMMAJtv: On June S. 1980. EPA listed
 inorganic srsenic ss a hssardous sir
 pollutant under Section 112 of the Clean
 Air Act. Pursusnt to Section 112. EPA if
 proposing strrdards for the following
 categories of ..*urces of emissions of
 inorganic sroenic high-arsenic primsry
 copper smelters. low-arsenic pnmary
 copper imeltert, snd glass
 manufacturing planu. EPA identified
 other categories of sources emitting
 inorgsnic srsenic snd after careful
. study, determined that the proposal of
 standards for these categories of sources
 is not warranted at this time. These
 categories of sources sre primsry lesd
 smelters, secondary lesd smelters.
 primsry sine smelters, sine o^lde plants.
 cotton gins, snd srsenic chemical
 manufacturing plants.
 AOOftesacs: See
                     TiOM CONTACTS

 Public Hssrings sod Related Information
   Comments. Comments must be
 received on or before September 30.
   Public Hearing. Two public hearings
 will be held. The first hearing will be
 held in Washington, D.C.. on August 23.
 24. snd 23.1983. beginning at WO a.m.
 each day. This hearing will consist of
 two separates sessions. The first session
 will be for the purpose of receiving
 comments on the listing of arsenic as a
 harasdous pollutant. The second session
 will be for the purpose of receiving
 comments on the content of the
 proposed regulations. The order of items
 on the agenda of the second session will
 be: (1) high>srsenic coppers smellers. (2)
 low-srsinic copper smelters. (3) glass
 manufacturing plants, and (4) others.
 Persons planning to attend the first
 hearing may call mrs. Naomi Durkee
 (919) 541-5578 after August 18.1983. to
                       obtsin sn estimated time and date at
                       which each lubject will be addressed.
                         The second hearing will be held in
                       Tscoma. Washington, on August 30.
                       1983. This hearing will be for the
                       purpose of receiving comments on the
                       proposed standards for high-arsenic
                       copper smelters. This hes* ng will be
                       held fromm 12:00 noon to l«»flO p.m. and
                       may be continued on August 31.1983. if
                       necessary to allow all persons wishing
                       to spesk an opportunity to do so.
                         Request to Speak at Hearing. Persons
                       wishing to present oral testimony st the
                       first hearing must notify Mrs. Nsomi
                       Durkee by August 15,1983. at telephone
                       number (919) 541-4578 or mailing
                       address: Standards Development
                       Branch. MD-13. U.S. Environmental
                       Protection Agency. Research Triangle
                       Park. N.C. 27711.
                         Persons wishing to present oral
                       testimony at the second hearing must
                       notify Ms. Laurie Krai by August  23.
                       1983. at telephone number (208) 442-1089
                       or mailing address: Air Programs
                       Branch. U.S. Environmental Protection
                       Agency. Region X.1200 8th Avenue.
                       Seattle. Washington. 98101.

                         Comment!. Comments should be
                       submitted (in duplicate if possible) to:
                       Central Docket Section (LE-131).  U.S.
                       Environmental Protection Agency. 401 M
                       Street. S.W.. Washington. D.C 20460.
                       Specify the following Docket Numbers:
                       OAQPS-Tft-S  Usiintofiirsenkasa
                         iMMiiluus pollutant
                       A-ao-40  High-arsenic and low*an*nic
                         copper smelten
                       A-e»-6 CUM manufacturing plants
                       A-S3-9 Secondary lead
                       A-43-10  Cotton fins
                       A-*M 1  Zinc oaide plants
                       A-43-Z3  Primary sine primary I id. arsenic
                         chemical manufacturing
                         Public Hearing. The public leering to
                       be held on August 23.24 and 25.1983.
                       will be held at the Department of
                       Agriculture. Thomas Jefferson
                       Auditorium. South Building. 14th  snd
                       Independence Ave~ SW- Washington.
                         The public hearing to be held on
                       August 30.1983. wit] be held at the
                       Tacoma Bicentennial Pavilion. Rotunda
                       Room. 1313 Market Street Tacoma.
                         Background Information Document.
                       Background Information documents
                       (BID'S) for the proposed standards may
                       be obtained from the  U.S. Environmental
                       Protection Agency library (MD-35).
                       Research Triangle Park. North Carolina
                       27711. telephone 919-441-2777. please
                         EPA 450/3-83-009S Inorganic Arsenic
                       Emissions From High-Arsenic Primary
Copper Smelters—Background
Information for Proposed Standards
  EPA 4SO/3-83-010a inorganic Arse
Emissions From Low-Arsenic Pnmar
Copper Smelters—Background
Information for Proposed Standards.
  EPA 4SO/3-B3-011S Inorganic Arse
Emissions From Class Manufsctunn.
Plants—Background Information for
Proposed Standards.
  EPA 450/5-82-005 Preliminary Stu
of Sources of inorgsnic Arsenic.
  Dockets. Dockets containing
supporting information used in
developing the proposed standards a
available for public inspection and
copying between 8:00 a.m. and 4:00 p
Monday through Friday, at EPA s
Central Docket Section. West Tower
Lobby. Gallery 1. Waterside Mall. 40
Street. SW.. Washington. D.C. 20460.
reasonable fe« may be charged for
copying. The following dockets are
OAQPS-79-a  Listing of arsenic as a
  hmurdou* pollutant
A-SO-W  High-arsenic and Io«v-*rsemc
  rapper smaller*
A-63-8 Class manufacturing plants
A-S1-0 Secondary lead
A-63-10  Cotton gins
A-ta-11  Zinc oxide plants
A-O-21  Pnmary tine, pnmary lead, an
  chemical manufacturing

  The docket A-80-40. which contat
the supporting information for the
proposed stsndards for high-arsenic
tow-arsenic copper smellers, will ah
available for inspection and copying
the EPA Region X office in Seattle.
Washington. Persons wishing to vie<
this docket should contact Ms. Laun
Krai at telephone number (2061442-.
or at mailing address: Air Programs
Branch. U.S. Environmental Protect!
Agency. Region X. 1200 6th Avenue.
Seattle. Washington. 98101.

              Fedora! Register / Vol. 48.  No. 140 / Wednesday, July 20. 1983 / Proposed Rules
  Thi proposed standards would
regulate Inorganic arsenic emissions
from primary copper smtltsrs thai
proctss fetd material with u annual
avtraft inorganic arsmie content of a?
weight ptrosnt or more. Ths propOMd
standards would rsquirs th« ust of bast
available technology (BAT) to limit
secondary inorganic arsenic tmlaslons
from copper converting operations.
Secondary inetisaic arsenic •missions
are emissions that escape capture from
the primary emissioa control system.
The BAT for the capture of secondary
Inorganic arsenic emissions from
converter chaffing, blowing, skimming.
holding, and pouring operations Is a
secondary hood system consisting of a
fixed enclosure with a horizontal air
cut MU.I. For collection of secondary
inorganic arsenic emissions. SAT is a
bsghouse or equivalent control  device.
The proposed standards era expressed
in terms of equipment specifications for
the capture system and a  maximum
allowable paniculate emission  limit for
the collection device. Particulate
emissions from the collection device
would not be permitted to exceed 114
milligrams of particulates per dry
standard cubic meter of exhaust gas
(mg/dscm). This limit reflects BAT for
collection of secondary inorganic
erienic emissions.
  To determine the applicability of the
proposed standards to a primary copper
smelter, the inorganic arsenic content of
the feed materials would  be measured
ut ing the proposed Reference Method
108A. To determine compliance with the
proposed particulale emission limit
Reference Methods 1.2.3. and S in
Appendix A of 40 CFR Part 60 would be
used. Continuous opadty monitoring of
gases exhausted from a particulate
control device would be required to
ensure the control device  is being
properly operated and maintained.
Continuous monitoring of airflow would
be required to ensure the secondary
hood system U being properly operated
and maintained.
Summary of Health. EoviraaBoatal.

  The proposed standards would affect
primary copper smelters that process
feed material having an annual average
Inorganic arsenic content of OJ weight
percent or more. This category is
defined as high-arsaaie>thronghpnt
•matters. The only existing primary
copper smelter in tha high-arsenic-
and operated by ASARCO. Incorporated
(ASARCO) and located In Tacoma,
Washington. The animal average
inorganic arsenic content of the feed
material la not expected to be Increesed
to 0.7 percent or above at any other
existing smeller, and no new smelters
are projected to be built For this rssson
only the ASARCO smelter located to
Tacoma. Washington (hereafter referred
to as the ASARCO-Tacoma smelter).
has been analyzed for the purpose of
calculating the health, environmental.
economic and energy impacts of the
piopossd standards.
  As will be discussed in the next
section, to facilitate regulatory analysis
EPA baa separated the primary copper
smelting Industry Into two source
categories baaed on the annual average
inorganic arsenic content of the smeller
feed material. Primary copper smelters
which process feed materiel with en
annual average inorganic arsenic
content less than Oi7 weight percent are
addressed in Part ID of this preamble.
  The proposed standards would reduce
totel Inorganic arsenic emissions from
the ASARCO-Tacoma smelter from the
current level of 282 mogegrems (Mg) (311
tons) per year to a level of 172 Mg (189
tons) per year. As a result of this
reduction in inorganic arsenic emissions.
It is estimated that (he number of
incidences of lung cancer due to
inorganic arsenic exposure for the
spproximately 370400 people living
within ebout 20 kilometers (liS miles)
of the ASARCO-Tacoma smelter would
be reduced from a range of LI to 174
incidences per year to a range of 0.2 to
3.4 incidences per year. The proposed
standards would reduce the estimated
maximum lifetime risk from exposure to
airborne inorganic arsenic from a range
of 24 to 37 In 100 to a range of OJi to 8,2
in 100. The maximum lifetime risk
represents the probability of a person
contracting cancer who has been
exposed continuously during a 70-year
period to the maximum annual inorganic
arsenic concentration due to inorganic
arsenic emissions from the ASARCO-
Tacoma smelter. (These estimated    '*!
health impede were calculated based
on a number of assumptions and contain
considerable uncertainty u discussed in
Part I of this preamble and in Appendix
E of to background Information
  Application of the controls
by the piopossd standards would
increase the amount of solid waste fl.e,
collected particulate matter containing
inorganic arsenic) entering the
ASARCO-Taooma smelter waste
disposal system by approximately 11
gtgsgrama (Cg) (12400 tens) per year.
Currently, the ASARCO-Tecena smelter
generates approximately 182 Cg (200400
tone) per year of solid waste (including
slag)- The-additional amount of solid
waste generated can be handled by the
existing waste handling system at the
smelter. Because the control systems
expected to be used to achieve the
proposed standards are dry systems.
there would be no water pollution
  Energy impacts under the proposed
standards would be increased electrical
power consumption. The annual energy
requirement for the ASARCO-Tacoms
smelter Is approximately 24 x 10*
kilowatt-hours per year (kWh/y).
Additional energy requirements at the
ASARCO»Tecema smelter das to the
proposed standards are estimsted to be
approximately 14x10' kWh/y.
representing an increase in the ennui

Federal  Register /  Vol.- 48. No.  140 / Wednesday.  July 20. 1983  /  Proposed  Rules
 smeller energy consumption of about O.S
   For the ASARCO-Tacoma smeller.   :
 capital and annuitized costs required lo
 meet the proposed standards would be
 approximately S3.5 miTTlon and Sl.S
 million, respectively. The primary
 economic impacts associated with the
 proposed standards arc projected
 decreases in profitability for the
 ASARCO-Tacoma smelter. It is
 anticipated that the proposed standards
 will not adversely affect the economic
 viability of the smelter or employment at
 the smelter. In addition, it is estimated
 that the proposed standards could result
 in an increase in the price of. copper of
 up to 0.8 percent.

 Selection of Source Category
   Copper smelling involves the
 processing of copper-bearing ores
 containing varying concentrations of
 inorganic arsenic. EPA estimates  that
 current controlled emissions of
 inorganic arsenic from primary copper
 smelters are 1.012 megagrams |Mg)
 (1.116 tona) per year.
  Several studies have assessed health
 problems in communities  where primary
 copper smellers are located. Increased
 lung cancer has been reported among
 male and female residents living near a
 primary copper smeller located in
 Anaconda. Montana (this smelter was
 permanently closed in 1981). The
 National Cancer Institute  has released •
 study showing excess mortality from
 respiratory cancer in counties where
 primary copper smelters are located.);-/)
  *!PA initiated a study in 1977 of the
 populations exposed to various amhi»ni
 air concentrations of inorganic arsenic.
 This study, in summarizing 1974 data
 collected by EPA's National Air
 Sampling Network (NASN). shows that
 the annual average concentration of
 inorganic arsenic for five urban areas
 within 80 kilometers of selected smellers
 was  10 times greater than the annual
 average for all of the sites (in excess of
 250)  in the nationwide network. At a site
 within 18 kilometers of the ASARCO-
 Tacoma smelter, the annual average
 was  more than 25 times the national
  Based on information provided  by the
 copper smelling industry.  EPA has
 determined that the ASARCO-Tacoma
 smelter processes feed containing a
 higher concentration of inorganic
 arsenic tlian any other primary copper
 smelter in the United Slates. The
 ASARCO-Tacoma smelter is a custom
 smeller. ASARCO purchases ore
concentrates from other mining and
milling producers to process at ils
                        Tacoma smelter. Typically, feed
                        material containing on the average 4.0
                        weight percent.inorganic arsenic is
                        processed at the ASARCO-Tacoma
                        smeller at the rale of 940 kilograms of
                        inorganic arsenic per hour (kg/h). The
                        level of inorganic arsenic conr«nir.iiion
                        in the feed materials processed at the
                        ASARCO-Tacoma smelter is an order of
                        magnitude greater than the level
                        processed at the other 14 primary copper
                        smelters. The second highest average
                        inorganic arsenic content in the feed
                        material processed at a domestic
                        smelter is 0.6 weight percent. The
                        second highest average process rate of
                        inorganic arsenic al a domestic smelter
                        is approximately 170 kg/h. in fact, the
                        inorganic arsenic process rate  for the
                        ASARCO-Tacoma smelter is
                       . significantly greater than the combined
                        inorganic arsenic process rate  of 625 kg/
                        h for the other 14 smellers.
                          Because of the potential for high
                        inorganic arsenic emissions and the
                        proximity of the population, calculated
                        risks and cancer incidence are
                        substantially higher for the ASARCO-
                        Tacoma smelter than for other smelters.
                        Consequently, the benefits associated
                        with the application of specific control
                        technologies to the ASARCO-Taroma
                        smelter versus the other smelters are
                        significantly different when considered
                        in terms of emission and risk reduction.
                       costs, energy, and other impacts. For
                        this reason. EPA believes it is
                        reasonable for purposes of regulation to
                        separate smelter* into two source
                       categories based on the annual average
                        inorganic arsenic concentration in the
                          The source category for high-arsenic-
                        throughput smellers is primary copper
                       smelters processing feed with an annual
                       average inorganic arsenic content of 0.7
                       percent or more. The value 0.7  percent
                        was selected based on the consideration
                        of the inorganic arsenic content of the
                        feed materials processed at the exiating
                        smelters other than the ASARCO-
                       Tacoma smaller. The regulatory analysis
                        of the 14 existing smelters which
                        process feed material with an annual
                        average inorganic arsenic content less
                        than 0.7 weight percent is presented n.
                        Part III of this preamble.
                          EPA has. as a matter of prudent health
                        policy, taken the position that human
                        carcinogens must be treated aa posing
                        some risk of cancer at any non-zone
                        level of exposure. Therefore, in
                       conjunction with the Administrator's
                       determination that (1) there is a high
                        probability that Inorganic arsenic is
                        carcinogenic to humans, and (2) that
                        there  > significant public exposure to
                        inorganic arsenic emissions from the
                        ASARCO-Tacoma smelter he
 Administrator has determined that
 inorganic arsenic emissions from nign-
 Mrsenic-ihroughput smelters are
 significant e metals in the ore. The

               Federal Regular  /  Vol. 46.  No. 140  /  Wednesday. July 20. 1983 / Proposed Rules
purpose of smelting ii to separate the
copper from the iron, sulfur, and other
impurities present in the ore
  Primary copper smelUag involves
three basic steps. First, the copper
sulfide ore concentrates are heated in a
roaster to remove a portion of the sulfur
contained in the concentrate. The solid
material produced by a roaster is called
"calcine." The calcine is loaded into
small rail cars (called "larry cars"). This
operation is called  "calcine
  The larry cars transfer the calcine to a
smelling furnace. At most smelters, raw
copper sulfide ore concentrate is
charged directly to the smelting furnace.
in the smelling furnace, the calcine or
raw. unroasted ore concentrate is
heated to form a molten bath containing
separate layers of matte (an impure
mixture of copper and iron sulfide) and
slag (a mixture of nonmetallic
impurities). Molten slag is skimmed from
the upper layer of the bath and poured
from openings in the furnace walls
(called "ports") into inclined troughs
(called "launders"), which empty the
slag into a vessel mounted on a small
rail car (called a "slag pot"). This
operation is called "slag tapping."
Molten matte is poured from a second
set of furnace ports into launders, which
empty the matte into ladles. This
operation is called "matte tapping."
  The ladle is transported by an
overhead crane to a copper converter.
The molten matte is poured from the
ladle into a large opening on the top of
the converter vessel. Air is blown into
.... converter to first oxidize the iron
suifide in the matte. The resulting iron
silicate slag is  poured directly from the
converter mouth into a ladle. When all
of the iron is oxidized and removed, the
remaining copper sulfide is oxidized to
form a high-purity copper product
(called "blister copper"). The blister
copper is poured directly from the
converter into a ladle for transfer to an
anode furnace (for further refining of the
copper) or directly lo the anode casting
area (for casting of the copper into
copper anodes).
  Roaster and smelting furnace offgaae*
are produced by the combustion of fuel
and the reaction of materials in the high-
temperature environments. Converter
offgases result from blowing air through
the matte and the reaction of materials
in the molten matte, inorganic arsenic in
the ore concentrates is volatized during
roasting, smelling, and converting, and
is exhausted from the process
equipment in the^offgases. Offgases
discharged from roasters, smelling
furnaces, and converters, in the absence
of any controls, would have the highest
inorganic arsenic emissions of any of
ihe copper smelting sources at the
ASARCO-Tacoma smeller. An inorganic
arsenic material balance was provided
by ASARCO and reviewed by EPA to
inventory the inorganic arsenic Inputs
versus outputs from each process at the
ASARCO-Tacoma smeller. The material
balance shows that the inorganic
arsenic emission rates in the absence of
any controls would be 255 kg/h for the
roasters. 608 kg/h for the smelting
furnace, and 207 kg/h for the converters.
  During converting, most of the
remaining amount of inorganic arsenic
and other impurities originally in the
copper ore are removed from the copper
matte to produce blister copper (98 to 99
percent pure copper). Blister copper
from the converters may be further
refined in anode furnaces prior to
casting of copper anodes (solid slabs of
blister copper). Because of the small
quantity of inorganic arsenic remaining
in the blister copper charged lo the
anode furnace, inorganic arsenic
emissions from anode furnaces are very
low when compared to the inorganic
arsenic emissions from roasters.
smelling furnaces, or converters. The
material balance for teh ASARCO-
Tacoma smelter shows that inorganic
arsenic emissions from anode furnaces
in the absence of any controls would be
0.4 kg/h.
  The ASARCO-Tacoma smelter is the
only primary copper smelter that
recovers arsenic from collected waste
materials. Oust collected In the flues and
control devices at the smeller is
processed to produce arsenic trioxide
for sale to arsenic chemical
manufacturing companies. In addition.
metallic arsenic is produced at the
smelter site. The material balance
shows that inorganic arsenic emissions
from the arsenic trioxide and metallic
arsenic manufacturing processes in the
absence of any controls would be 378
  Secondary inorganic arsenic
emissions from converters are those
emissions that escape capture from the
primary emission control system. When
the converter is rolled out forchargir."
matte into the converter mouth,
skimming slag formed In the converter.
or pouring blister copper into a ladle, the
primary hood ia moved up and away
from the converter mouth to provide
clearance for the overhead crane and
ladle. As a result, charging, skimming.
and pouring operations can emit
significant amounts of secondary
inorganic arsenic because these
operations-occur outside the range of the
converter's primary offgas exhaust
hood. Additional secondary inorganic
arsenic emissions also escape capture
 by the primary offgas exhaust hood
 during blowing and holding operations.
 For ihe ASARCO-Tacoma
 material balance shows that
 secondary inorganic arsenic emisns
 rate from converter operations in the
 absence of any controls would be 14 kg/
   Secondary inorganic arsenic    "
 emissions also escape to the atmosphere
 during calcine discharging at Ihe roaster
 and during matte tapping and slag
 tapping at the smelting furnace. An
 estimate based on the material balance
 for the ASARCO-Tacoma smelter show:
 that inorganic arsenic emissions from
 matte tapping in the absence of any
 controls would be 4 kg/h. inorganic
 arsenic emissions from calcine
 discharging and slag tapping are
 estimated to be less than 1 kg/h.
 Secondary inorganic arsenic emissions
 from anode  furnace operations are less
 than 0.1 kg/h. Miscellaneous sources of
 secondary inorganic emissions from
 primary copper smelter operations
 include the handling and transfer of dus
 from control device storage hoppers.
 equipment flues, and dust chambers. At
 the ASARCO-Tacoma smelter these
 activities are conducted at many
 locations throughout the plant. Althougr
 the amount of inorganic arsenic
 emissions at each location is
 the cumulative total of emissic
 many locations can be a signific
 quantity. The material balance for the
. ASARCO-Tacoma smelter shows that
 secondary inorganic arsenic emissions
 from miscellaneous sources would be
 about Q kg/h in the abaense of any
 Policy for Determining Control Levels

   For this source category, which
 consists of only the ASARCO-Tacoma
 smelter, a three-step approach has bee:
 followed to determine the control
 requirements being proposed. This
 approach is baaed on the policy
 discussed in Part i of this preamble.
   The first step consists of determining
 whether current controls at the
 ASARCO-Tacoma smelter reflect
 application of BAT. BAT is the
 technology which, in the judgment of
 EPA. is the most advanced level of
 control which is adequately
 demonstrated considering
 environmental, energy, and economic
 impacts. BAT considers economic
 feasibility: and. for this smelter. BAT
 does not exceed the most advanced
 level of control that the smelter could
 afford without closing.
   For those emission points
 is in place. EPA determines
 NESHAP standard is needed to assure

V Vol. 4aV No. 140 /  Wednesday. July 20^  1983 / Proposed Rules
 that BAT will remain in place and will
 be properly operated and maintained. A
 primary consideration is the existence of
 other Federally enforceable standards. If
 BAT is not in place on specific emission
 points or if there is reason to expect that
 BAT may not remain in operation, these
 emission points are identified for
 development of standards.
   The second step involves the selection
 of BAT for the emission points at the
 ASARCO-Tacoma smelter identified for
 the development of standards. To select
 BAT. regulatory alternatives are defined
 based on demonstrated control
 technology. The environmental.
 economic, and energy impacts of the
 alternatives are determined. Based on
 sn assessment of these impacts, one of
 the alternatives is selected as BAT.
   The third step involves consideration
 of regulatory alternatives beyond BAT
 for all of the inorganic arsenic emission
 points at the ASARCO-Tacoma smelter.
 The risk of cancer incidence due to
 inorganic arsenic exposure in  the
 population  distributed around the
 ASARCO-Tacoma  smeller is estimated.
 This estimated risk which remains after
 application of BAT is evaluated
 considering costs, economic impacts.
 risk reduction, and other impacts that
 would result if a more stringent
 alternative  were selected. If the residual
 risk is fudged not to be unreasonable
 considering the other impacts or beyond
 BAT controls, more stringent controls  .
 than BAT are not required. However, if
 the residual risk is  judged to be
 unreasonable, then an alternative more
 stringent than BAT would be required.
 Determination of the  Adequacy of
 Current Controls
   Inorganic arsenic emission sources at
 the ASARCO-Tacoma smelter are
 currently controlled using a variety of
 capture and collection techniques.
 Capture techniques are used to gather
 and confine secondary inorganic arsenic
 emissions and to transport them lo a
 collection device. Collection techniques
 are used to remove inorganic arsenic
 from process offgases and captured
 gases prior  lo venting the gases to the
 atmosphere. Each inorganic arsenic
 emission source at the ASARCO-
 Tacoma smelter was  examined by EPA
 to determine the extent to which
 inorganic arsenic emissions are
 currently controlled and whether the
 level of control represents BAT.
  Controls currently in place at the
 ASARCO-Tacoma  smeller collect
 inorganic arsenic emissions in the
 roaster, smelting furnace, converter, and
anode furnace process offgases. During
these process operations, inorganic
arsenic is volatilized  and emitted as a
                        metallic oxide vapor in the process
                        offgases. By cooling the process
                        offgases. the inorganic arsenic vapor
                        condenses to form inorganic arsenic
                        particulates. which can be collected in a
                        conventional paniculate control device.
                        Because of the high-inorganic-arsenic
                        content of the feed materials process at
                        the ASARCO-Tacoma smelter, the
                        concentration of inorganic arsenic in the
                        process offgases greatly exceeds (he
                        inorganic arsenic saturation
                        concentration at gas temperatures less
                        than 121* C (250'F). Consequently, for
                        process offgases cooled to temperatures
                        below 121* C. inorganic arsenic emission
                        control levels can be achieved that
                        approach the performamce capability of
                        a control device for collecting total
                        particulate matter.
                          Roaster process offgases at the
                        ASARCO-Tacoma smelter are cooled to
                        a temperature less than 121* C and the
                        inorganic arsenic particuiatea are
                        collected in a baghouse. The smelting
                        furnace process offgases are cooled to a
                        temperature of 92* C and the inorganic
                        arsenic particulates are collected in an
                        electrostatic precipitator. Converter
                        process offgases are exhausted to a
                        liquid SOt plant or a single-contact
                        sulfuric acid plant Because the presence
                        of solid and gaseous contaminants can
                        cause serious difficulties in the
                        operation of the SO* or acid plants, the
                        converter process offgases are first
                        cleaned by passing the gases through a
                        water spray chamber, an electrostatic
                        precipitator. scrubbers, and mist
                        precipitators. This gas cleaning process
                        removes over 99 percent of the
                        contaminants, including inorganic
                        arsenic, from the offgases prior to
                        entering the SO* or acid plants. In the
                        event that the volume of converter.
                        process offgases exceeds the capacity of
                        the SOi and acid plants or when the
                        plants are not operating, the excess
                        converter offgases are diverted to an
                        electrostatic precipitator. This
                        electrostatic precipitator also serves aa
                        the full-lime  contra) device for the anode
                        furnace process offgases. Coaling of the
                        gases in the ducting lowers the gas
                        temperature to leaa than 120* C prior to
                        entering the electrostatic precipitator.
                          Controls for inorganic arsenic
                        emissions from roaster, smelting
                        furnace, converter, and anode furance
                        proceas offgases are in place at the
                        ASARCO-Tacoma amelter in order to
                        comply with existing total particulate
                        emission regulations of the Puget Sound
                        Air Pollution Control Agency {PSAPCA).
                        These regulations are expressed in
                        leans of very stringent process weight
                        particulate emission limits. The
                        PSAPCA regulations are included as
                        part of the Washington State
                                              implementation plan (SIP) for attaining
                                              the Federal ambient air quality standard
                                              For particulate matter and. therefore, are
                                              Federally enforceable regulations.
                                                Roaster, smelling furnace, converter.
                                              and anode furnace process offgases are
                                              potentially significant sources of
                                              inorganic arsenic emissions. Because of
                                              the high inorganic arsenic vapor
                                              concentrations in the process offgases *<
                                              a high-arsenic-throughput smelter.
                                              cooling of the offgases to below 121* C
                                              results in  condensation of the vapor to
                                              form particulates. Thus, collection of the
                                              inorganic arsenic particulates  in
                                              properly designed and operated
                                              particulate control  devices can
                                              effectively control the emission to the
                                              atmosphere of inorganic arsenic in the.
                                              process offgases. The types of control
                                              systems currently used at the ASARCO-
                                              Tacoma smelter to collect inorganic
                                              arsenic from process offgases achieve
                                              inorganic arsenic collection efficiencies
                                              greater than 96 percent.
                                               The control systems in place at the
                                              ASARCO-Tacoma  smelter to control
                                              roaster, smelting furnace, converter, and
                                              anode furnace process offgas inorganic
                                              arsenic emissions represent the best
                                              demonstrated level of control
                                              considering economic feasibility.
                                              Therefore, the roaster, smelting furnace.
                                              converter, and anode furnace process
                                              offgases are already controlled using
                                              BAT. Existing Fedesally enforceable
                                              regulations require the controls to
                                              remain in place and to be properly
                                              operated and maintained to reduce total
                                              particulate matter emissions. These
                                              regulations serve to assure that BAT for
                                              inorganic arsenic will remain in place.
                                              Therefore, additional standards based
                                              on  BAT are not necessary at this time
                                              for smelter roaster, smelting furnace.
                                              converter, or anode furnace process
                                               Existing controls in place at the
                                              ASARCO-Tacoma  smelter significantly
                                              reduce the quantity of Inorganic arsenic
                                              emissions from the arsenic trioxide and
                                              metallic arsenic manufacturing
                                              processes. Arsenic laden offgases from  .
                                              the Godfrey roasters pasa through the
                                              arsenic kitchens where arsenic trioxide
                                              condenses on the walls of the chambers
                                              and is collected as a  product Gases
                                              passing through the kitchens are vented
                                              to a baghouse. The temperature of the
                                              gases at the inlet to the baghouse is less
                                              than 121* C Offgases from the metallic
                                              arsenic furnaces are also vented to the
                                              same baghouse. Inorganic  arsenic
                                              emission  points at  conveyors, charge
                                              hoppers, storage bunkers, and the
                                              barreling  and carioading stations are
                                              controlled by capturing the emissions
                                              using local hoods and venting the

               Federal Register  /  Vol. 48. No. 140 / Wednesday. July 20.  1983 / Proposed Rules
emissions lo tevenl small baghouies.
These control* are in place at the
ASARCO-Tacoma smelter to comply
with PSAPCA arsenic and paniculate
regulations and with the y-.S.
Occupational Safety and Health
Administration (OSHA) inorgnnic
arsenic worker exposure iland«rd.
  The composition of the*total
paniculate mailer emissions from the
•irsenic manufacturing processes at the
ASARCO-Tacoma smeller is inorganic
arsenic particulates. All inorganic
Hrsente emission points are controlled
by collecting the particuiale emissions
using baghouies. The major procesa
offgas i (reams are combined and vented
to a new baghouse installed in 1982. The
baghouse design represents the moat
advanced level of particuiale matter
collection technology demonstrated in
rfaie. Additional reduction inorganic
arsenic emissions is not possible using
Available control technology. Therefore.
F.PA considers the controls at the
ASARCO-Tacom* smeller arsenic
manufacturing plant to be BAT. Since
ihese controls are required by Federally
enforceable regulations. EPA is not
developing additional BAT standards
for arsenic manufacturing processes at
this lime.
  The major source of secondary
arsenic emissions at the ASARCO-
Tacoma smelter is the converter
operations. ASARCO has recently
installed a prototype control system on
one of the three converters used al the
smeller for copper converting
operations. (A fourth converter is used
as - kolding furnace only.) A secondary
hood system consisting of a fixed
enclosure with a horizontal air curtain ia
usrd to capture the secondary inorganic
arsenic emissions. The captured
emissions are vented to an electrostatic
precipitator (designated by ASARCO as
the No. 2 ESP). The company ia planning
to install similar secondary hood
systems on the other two converters and
to vent the captured emissions to the
No. 2 ESP. However, regulations do not
exist thai would apedfically require the
use of BAT to limit aecondary inorganic
arsenic emissions Iron convener
operations. Because of the potential for
converter operations to emit large
quantities of aecondary Inorganic
arsenic, and because of the
demonstrated availability of controls for
these emissions EPA decided to develop
standards baaed, as * "H'mmum. on BAT
for secondary inorganic arsenic
emissions from converter operations.
  Smelting furnace secondary inorganic
arsenic emissions from matte tapping
and slag tapping ere captured end
collected at the ASAHCO-Ta
 smelter. Copper matte or slag flows from
 ports in the furnace walls through a
 launder which directs the molten
 material to a point where il is
 transferred to a ladle or slag pot. At (he
 ASARCO-Tacoma smeller, the matte
 lapping launders are enclosed by
 semicircular covers. Slag lapping
 launders are covered by fixed hoods
 mounted above the troughs. Local
 exhaust hoods are mounted about 1
 meter (3 feet) above each tap port. Al
 each launder-lc-ladle transfer point for
 matte tapping, e retractable exhaust
 hood is used to capture emissions
 generated at the ladle. An overhead
 crane places the ladle on the floor in
 front of the launder. The hood is then
 lowered over the ladle prior to tapping
 and is raised after the lap is complete.
 The overhead crane returns and picks
 up (he ladle of molten matte for tranafer
 to the converters. At each launder-to-
 slag pot transfer point for slag tapping.
 large fixed exhaust hoods are mounted
 above the slag pot transfer point. The
 captured secondary emissions from
 matte rapping and slag lapping aie
 vented to the No. 2 ESP.
   At the ASARCO-Tacoma smeller, all
 emission points from smelling furnace
 matte tapping or slag tapping are
 enclosed or ere covered by local
 exhaust hoods. In EPA's judgment, this
 capture system, if properly operated end
 maintained, represents BAT for capture
 of secondary emissions from smelting
 furnace matte lapping end slag tapping
 because no other demonstrated
 technology can achieve e higher level of
 capture efficiency. The capture system
 is in piece to fulfill e tripartite
 agreement between ASARCO. OSHA.
 and the United Sleelworkers of America
 (union representing workers et the
 ASARCO-Tacoma smelter). The
 agreement specifies the engineering
 controls tod work practice! lo be
 implemented at tht ASARCO-Tacoma
 smelter for achieving compliance with
.the Federal OSHA inorganic arsenic
 worker exposure standard and,
 therefore, ia Federally enforceable.
 Although not specified in the agreement.
 the captured aecondary Inorganic
 arsenic emissions an vented to an
 electrostatic pndpitator for collection.
 The level of performance of this control
 device ia equivalent to the level of
 performance of BAT for collection of
 process Inorganic arsenic emissions.
 EPA has BO reason to believe that
 ASARCO will not continue to properly
 operate and maintain the electrostatic
 predpitaton therefore. EPA concluded
 :hat BAT ia In place at the ASARCO-
 Tacoma smelter for capture and
 collection of secondary Inorganic
arsenic emissions from smelting furnace
matte lapping and slag tapping.
  Roaster secondary inorganic arsa
emissions from calcine discharge al
also captured and collected al the
ASARCO-Tacoma smelter. Calcine is
gravity loaded into larry cars from
hoppers located at the bottom of the
roaster. An exhaust hood is mounted on
either side of each hopper. A spring-
loaded top having three small openings
covers each larry car. When the larry
car is positioned under the hopper, the
openings in the car top align with the
hopper outlet and the two exhausl
hoods. Because the top is spring-loaded.
a tight connection is achieved between
the top and the hopper outlet and hoods.
During loading, an induced draft fan is
HCtivaied to ventilate the spece under
the car top and to capture the emissions
generated by the loading operation. The
captured secondary emissions are
combined with the roaster offgases pnor
to venting to the baghouse. In addition
lo the local hoods located at the calcine
discharge point, the calcine hopper area
is enclosed to form a tunnel-like
structure. This area is ventilated with
the exhaust air being combined with the
exhausl air from the local exhaust
  The capture system used  al the
ASARCO-Tacoma smeller for captt^
secondary inorganic arsenic emissic
from roaster calcine discharge is the
most advanced technology
demonstrated. In EPA's judgment, this
system represents BAT. Similar to the
controls in place al :he ASARCO-
Tacoma smelter for smelting furnace
matte lapping and slag tapping, the
calcine discharge capture system is in
place lo fulfill the tripartite  agreement lo
achieve the OSHA inorganic arsenic
worker exposure standard. The captured
secondary inorganic arsenic emissions
are vented to the baghouse  which has
been determined to be BAT for
collection of inorganic arsenic emissions
from the roaster process offgases.
Therefore. BAT Is in place at the
ASARCO-Tacoma smeller for capture
end collection of secondary inorganic
emissions from roaster calcine
  To control secondary inorganic
arsenic emissions from the handling and
transfer of flue dust the ASARCO-
Tacoma smelter has implemented the
beat control practices available. All dust
conveyor systems are enclosed in dust-
tight housings. Hopper and  storage bins
are equipped with dust level indicate
Dust-tight connections era used to
transfer material from hopers and t   	
to vehicles. This equipment is in place to
fulfill the tripartite agreement to achieve

Federal Register /  Vol. 48. No. 140 /  Wednesday.  July 20. 1983  /  Proposed Rules
the OSHA worker exposure standard.
Because BAT is already required in
order to comply with existing Federal
regulations, additional standards based
on BAT are not necessary at this time
for miscellaneous sources of secondary
inorganic arsenic emissions at high-
arsenic-throughput smelters..  .
  The anode fumances in operation at
the ASARCO-Tscoma smeller arc of an
•typical design that is not used at
snyother primary copper smelter located
in the United States. Secondary
inorganic arsenic emissions (perhaps up
to 0.1 kg/h) escape to the atmosphere
from a large opening in the anode
furnace wall. This opening allows the
fumance operators to perform activities
necessary for refining the blister copper.
Secondary inorganic arsenic emissions
from the anode furnace could
conceivably be captured using an
elaborate secondary hood system.
However, the effectiveness of such e
theoretical capture system is uncertain
considering the design of the anode
furnaces and the nature of operations
required to operate the furnaces. EPA
believes that any capture system
designed to provide the necessary
access to the anode furnaces would
impose very high costs. Based on the
small reduction in total smelter
inorganic arsenic emissions that would
be expected to result from controlling
anode furnace secondary emissions, it is
EPA's judgment that the costs for
installing controls to capture the anode
furnace secondary inorganic arsenic
emissions are excessive. Therefore. EPA
iia* determined that the existing
equipment represents BAT and. as a
result, no standards are being developed
at this time for secondary inorganic
arsenic emissions from anode furnaces.
  In summary, roaster, smelling furnace.
and converter process offgases aa well
as anode furnace, arsenic plant, and flue
dust handling sources are judged to be
currently controlled using BAT. Also,
secondary inorganic emissions from
roaster calcine discharge, and smelting
furnace matte tapping and slag tipping
are captured and collected using BAT.
These controls are required by existing
Federally enforceable regulations or are
expected by EPA to remain in place and
to be properly operated and maintained.
With the exception of the prototype
secondary hood on one converter, no
controls are currently in place to limit
secondary emissions from the
converters. Therefore,  because capture
technology has been demonstrated. EPA
decided to develop standards based, as
a minumum. on BAT for secondary
emissions from converters.
                        Selection of BAT for Converters

                          Control Technology- Primary
                        converter hoods capture process
                        emissions during converter blowing
                        periods: but. during charging, skimming.
                        holding, or pouring operations, the
                        mouth of the converter is no longer
                        under the primary hood, and converter
                        emissions escape capture by the hood.
                        There are three alternative control
                        methods for capturing secondary
                        emissions from converter operations: (1)
                        fixed and retractable secondary hoods.
                        (2) air curtain secondary hoods, and (3)
                        building evacuation.
                          Four domestic smelters currently use
                        fixed secondary hoods to capture
                        converter secondary emissions. These
                        hoods are attached to the upper front
                        side of the converter primary hoods.
                        More complex retractable secondary
                        hood designs are used at one domestic
                        smelter and smelters in Jspan. Visual
                        observations made at two domestic
                        copper smelters showed that fixed end
                        retractable secondary hoods captured a
                        portion of the secondary emissions from
                        converter operations. However, the
                        capture efficiencies of existing fixed and
                        retractable secondary hood designs are
                        judged by EPA to be less than 90
                          A more advanced method for the
                        capture of convener secondary
                        emissions is the use of an air curtain
                        secondary hood. Walla are erected to
                        endoaa the sides and the back of the
                        area around the converter mouth. A
                        portion of the enclosure back wall is
                        formed by the primary hood. Openings
                        at the top and In the front of the
                        enclosure allow for movement of the
                        overhead crane cables and block, and
                        the ladle. Edges of the walls in contact
                        with the primary hood or the converter
                        vessel are sealed. A broad, horizontal
                        airstream blows across the entire width
                        of the open apace at the top of the
                        enclosure. This airstream is called en
                        "air curtain." The air curtain is produced
                        by blowing compressed air from a
                        narrow horlsontal atot extending the
                        length of a plenum along the top of ore
                        of the side walls. The air la directed to s
                        receiving hood along the top of the
                        opposite side wall An Induced draft fan
                        In the ducting behind the receiving hood
                        pulls the airstream Into the hood. When
                        the converter Is rolled out away from
                        the primary hood for charging.
                        skimming, or pouring, the air curtain
                        sweeps the converter offgases and
                        emissions which are generated by
                        material transfer between the converter
                        and the ladle Into the receiving hood.
                        The captured emissions art then vented
                        to a collection device or released
directly to the atmosphere through a
  The air curtain secondary hood has
been demonstrated as an effective
method for capturing converter
secondary emissions. For the past 3
years, air curtain secondary hoods hav>
been in place to control converter
secondary emissions at copper smeller'
in Japan. A prototype air curtain
secondary hood wes installed in 1962 c
one of the converters at the ASARCO-
Tacoma smelter.
  In Janus ry 1983. EPA conducted a te;
program designed to evaluate the
effectiveness of the capture of
secondary emissions by the prototype
•ir curtain secondery hood at the
ASARCO-Tacoma smelter. The capture
efficiency of the system was evaluated
by performing a gas tracer study snd
visual observations. The gas tracer
study involved injecting a gas tracer
inside the boundaries of the fixed
enclosure and measuring the amount o:
the gas tracer in the exhaust gases in tr
ducting downstream of the enclosure
receiving hood. The capture efficiency
was then calculated by a material
balance of the inlet and outlet tracer gf
mass flow rates. Based on the results o
this test program. EPA believes an sir
curtain tscondary hood is capable of
achieving an overall capture efficiency
of 95 percent.
  Capture of converter secondary
emissions by building evacuation is
accomplished by controlling the airflot
patterns within the building housing th
conveners and by maintaining a
sufficient air change or ventilation rale
Control of airflow in the ventilated are
is obtained by isolating it from other
areas and by the proper design and
placement of inlet and outlet openings
Proper location and sizing of inlel and
outlet openings provide effective airflc
patterns so that the secondary emisstc
cannot escape to adjacent areas or
recirculate within the area.
  EPA believes thst a well-designed
building evacuation system should be
capable of achieving at least 96 percer
capture efficiency of secondary
emissions. However, the building
evacuation systems currently used in
non-ferrous  metallurgical industry hsv
not demonstrated this level of control.
building evacuation system is being
used at the ASAFCO copper, lead, an
zinc smelter located in El Paso. Texas
to capture secondary emissions from
copper converters and a sine smelting
furnace operated Inside a building.
While preventing the venting of
secondary emissions to the ambient s
outside the building, use of the buildir
evacuation system at the ASARCO-E.

                        Register / Vol. «, No. 140 / Wednesday.  July 20. 1963 / Prooosed  KuleT
 Paso smelter hat resulted in deviled
 concentrations of inorganic arsenic.
 lead, and SO*, tnsidc.the building in
 addition to excessive heat buildup. To
 alleviate these unacceptable working
 conditions, building openings have been
 increased and roof ventitatort designed
 for emergency use only have been
 operated  routinely. As a result of
 increasing the number of building
 openings, the capture efficiency of the
 building evacuation system has been
 decreased. The building evacuation
 system as presently operated  at the
 ASARCO-E1 Paso smelter achieves a
 capture efficiency of less than 95
   The control technology for the
 collection of secondary inorganic
 arsenic emissions is based on the
 cooling of the exhaust gases to condense
 the inorganic arsenic vapors to form
 paniculate*, and the subsequent
 collection of the inorganic arsenic
 particulaiei in a conventional
 paniculate control device. Baghouae and
 electrostatic prectpitator control devices
 are currently used at primary copper
 smellers to collect secondary inorganic
 arsenic emissions as well as paniculate
 matter emissions.
   To evaluate the efficiency of a
 conventional paniculate control device.
 EPA tested the baghouse in place al the
 ASARCO-EI Paso smelter used for the
 collection of secondary emissions from
 the conveners. Emission measurements
 for inorganic arsenic and total
 particulars were conducted at the
 haahouse inlet and outlet for three test
 runs. At the baghouse outlet inorganic
 arsenic concentrations ranged from
 0.015 to 0.39 milligram per dry standard
 cubic meter of exhaust gas (mg/dscm).
 The corresponding total particulate
 concentrations at the baghouse outlet  •
 ranged from i.l to 11.6 mg/dscm. Gas
 temperatures at the baghouse  inlet were
 less than SO'C (112'F). The Inorganic
 arsenic collection efficiency was over 99.
 percent for two of the test runs and was
 greater than 94 percent for the third test
 run. The test results showed that the
 overall average inorganic arsenic
 collection efficiency of the baghouse for
 three lest runs was 90 percent. EPA
 concluded from the tests that a properly
 designed, operated and maintained
 baghouse or equivalent paniculate
 control device can achieve a collection
 efficiency of at least M percent for
 inorganic arsenic.
  Regulatory Alternatives. To determine
 the level of control that reflects BAT for
control of convener secondary
emissions, technical alternatives were
identified for reducing inorganic arsenic
 emissions from the ASARCO-Tacoma
   For the purpose of analysis, these
 alternatives are identified here and in
 the background information document
 as Regulatory Alternatives I and I!. For
 Regulatory Alternative I. no national
 emission standard would be established
 for inorganic arsenic emissions from
 high-arsenic-Uiroughput smelters. No
 additional controls beyc.id the controls
 already in place at the ASARCO-
 Tacoma smelter to comply with existing
 regulations (e.g. Washington State
 implementation plan. OSHA inorganic
 arsenic worker exposure standard)
 would be required. Regulatory
 Alternative 1 corresponds to the
 baseline level of control.
   Regulatory Alternative II represents
 control of secondary inorganic arsenic
 emissions from converter opertions at
 the ASARCO-Tacoma smeller. This
 alternative is based on capture of the
 secondary emissions using a secondary
 hood consisting of a fixed enclosure
 with a horizontal air curtain. The
 captured secondary emissions would be
 vented to a baghouse or equivalent
 control device for collection.
   Regulatory Alternative I (baseline
 case) would not change the existing air
 and non-air quality environmental
 impacts of operations at the ASARCO-
 Tacoma smeller. Total inorganic arsenic
 emissions from the ASARCO-Tacoma
 smelter would remain at the current
 level of 282 Mg (311 Ions) per year. In
 addition, there would be no energy or
 economic impacts associated with this
   Regulatory Alternative n would
 reduce total inorganic arsenic emissions
 from the ASARCO-Tacoma smelter by
 110 Mg (121 tons) per year to a level of
 172 Mg (199 tons) per year. The amount
 of collected paniculate matter
 containing inorganic arsenic would be
 approximately 11 gigagnuns (Cg) (12.000
 tons) per year. This would Increase the
 amount of solid wast* generated at the
 ASARCO-Tacoma smelter from 182 to
 193 Cg (200,000 to 213.000 tons) per year.
 an increase of about 6 percent The
 additional solid waste can be handled
 by the smelter's existing solid waste
.disposal system. Because the alternative
 is based on use of an electrostatic
 precipitalor. a dry paniculate collection
 device, there would be no water
 pollution impact.
   The energy impacts of Regulatory
 Alternative II would be increased
 electrical energy consumption. To
 operate the control system specified by
 the alternative, annual electrical energy
 consumption would be 1.5X10*
 kilowatt-hours per year (kWh/y), Total
  smelter energy consumption is
  approximately 2.9x10* kWh/y. Thus.
  Regulatory Alternative II would increase
  the total ASARCO-Tacoma electrjcjt
  energy consumption by 0.5 pc
   The capital costs for installing
  control system specified by Regulatory
 Alternative II is $3.5 million. This
 represents a major capital expenditure
 for ASARCO. However. ASARCO is a
 major publicly held corporation with a
 good credit rating and good access to
 financing. Even considering the
 possibility of additional capital
 expenditures for control equipment for
 the two ASARCO low-arsenic-
 throughput smelters (the ASARCO-EI
 Paso and Hayden primary copper
 smeller* are addressed in Pan IU of this
 preamble), il is EPA's determination that
 ASARCO would be able lo obtain the
 necessary capital lo install the control
 system al the ASARCO-Tacoma
 smelter. The ennualiied cost lo
 implement Regulatory Alternative li ia
 estimated to be $1.5 million. If ASARCO
 chooses to absorb the costs by reducing
 Us profit margin, the profitability of the
 ASARCO-Tacoma smelter could be
 reduced op to S percent If ASARCO
 chooses to maintain Its normal profit
 margin and attempts to recover the tostr
 by increcaing copper prices, the pr-.-s
 increase would amount to OJ to O.C-
   In summary, under Regulatory I
 Alternative IL total  smelter inorgi
 arsenic emissions would be reduced by
 39 percent from 282 Mg per year lo 172
 Mg per year. The reduction ia emissions
 would be achieved with a small increase
 in the amount of solid  waste generated
 al the amelter. There would be no water
 pollution Impact. Energy consumption at
 the smelter would be slightly increased.
 The primary economic impacts
 associated with this alternative are a
 projected modest decrease in
 profitablity for  the ASARCO-Tacoma
 smeller and a possible small increase in
 the price of copper.  In EPA's judgment.
 this alternative would not adversely
 affect the economic viability of the
 ASARCO-Tacoma smelter or
• employment at the smeller. Because a
 significant reduction in inorganic
 arsenic emissions from the ASARCO-
 Tacoma smelter is achievable with
 reasonable economic,  energy, and non-
 air quality environmental Impacts. EPA
 selected Regulatory Alternative It as
  It should be noted thai the level of
 control selected as BAT is based upon
 the Adminstralor's best judgement and
 the information available at this tir
 As discussed later, comments end
 information are being requested or!

Federal Re*ialtrf/' Vol.  4&yNo. 140. / Wednesday.  July-;M. 1963 / Proposed Rules
additional control measures. The final
deeiaion on BAT will reflect
consideration of the** comments and
may, therefore, include measures (e.g..
production curtailments or improved
operating and housekeeping practices)
which are not now included in
Alternative 11.
Consideration of Emittion Reduction
Beyond BA T and Decision on Bout for
Proposed Standards.
  After Identifying BAT, EPA
considered the estimated residual health
risks and possible control alternatives
that would reduce emissions to rates
lower then that achievable with BAT.
The health risk is expressed by the
number of incidences of cancer due to
inorganic arsenic exposure in the
population distributed around the
ASARCO-Tscoma smeiter. Based on
epidemiological studies. EPA derived a
unit risk number for exposure to
airborne inorganic arsenic. The unit risk
number is • measure of potency
expressed as the probability of cancer in
a person exposed to 1 jig/m ' of
airborne inorganic arsenic for a lifetime
(70 yean). Annual cancer incidence (the
number of cases per year) associated
with inorganic arsenic emissions from
'he ASARCO-Tacoma smelter is the
product of the total population exposure
around the smelter and the unit risk
number divided by 70 years. Total
exposure is determined by dispersion
modeling estimates of the inorganic
arsenic concentration in the ambient air
surrounding the smelter combined with
data for the distribution of the estimated
•>*« 000 people living within about 20
kilometers (12.5 miles) of the ASARCO-
Tacoma smeller. For the current level of
inorganic arsenic emissions from the
ASARCO-Tacoma smelter, the annual
cancer incidence is estimated to range
from l.l to 17.6 cases per year. With
BAT in place at the ASARCO-Tacoma
smelter for all of the significant
inorganic asenic emission points it ia
estimated that the annual cancer
incidence would be reduced to a range
of 0.2 to 3.4 cases per year. Application
of BAT would reduce the estimated
maximum lifetime risk from exposure to
airborne inorganic arsenic from a range
of 2.3 to 37 in 100 to a range of 0.58 to 0.2
in 100. The maximum lifetime risk
represents the probability of a person
contracting cancer who has been
continuously exposed during a 70-year
period to the maximum annual inorganic
arsenic concentration due to inorganic
arsenic emissions from the ASARCO-
Tacoma smelter.
  Ail known control alternatives wen
examined with the particular emphasis
on the further contol of secondary
                        emissions, which on the basis of
                        modeling results, cause the highest
                        ambient exposure and resultant health
                        risks. This examination, which included
                        evaluation of controls used on smelters
                        in both the United Slates and lapan as
                        well as the possibility of technology
                        transfer from other source categories.
                        identified no demonstrated
                        technological controls more efficient
                        than those Identified as BAT. Therefore.
                        the remaining alternatives are limited to
                        two basic categories: (I) production
                        limitations or curtailments and (2)
                        limitations on the smeller inorganic
                        arsenic throughput.
                        Impacts of Controls Beyond BA T
                          Without specific and detailed
                        knowledge of all economic informs lion.
                        which is known only to ASARCO, EPA
                        cannot estimate with certainty the
                        extent to which production curtailment
                        or limitation on inorganic arsenic feed
                        rale may be affordable. The smelter is
                        currently operating under a production
                        curtailment program designed to limit
                        ambient sulfur dioxide (SOi) levels. This
                        program, which EPA believes to achieve
                        at least a corresponding effect on
                        ambient inorganic arsenic
                        concentrations, currently results in
                        production curtailment of approximately
                        30 percent. When converter controls are
                        in place, the amount of curtailment
                        needed may be less but is expected to
                        be not less than 20 or 25 percent. Thus.
                        while further curtailments may be
                        possible, it is doubtful that the degree of
                        curtailment necessary to significantly
                        reduce risk (e.g.. a SO percent additional
                        curtailment would reduce the estimated
                        maximum risk from a range of 0.58 to 9.2
                        in 100 to a range of 0.29 to 4.8 in 100)
                        would be affordable.
                          An analysis of the importance of high-
                        inorganic-arsenic feed to the economic
                        viability of the ASARCO-Tacoma
                        smelter leads to the conclusion that the
                        smelter would probably close if high-
                        inorgsnic-arsenic-contact materials
                        could not be processed.  High-inorganic-
                        arsenic-content copper on concentrate
                        and lead ameiler by-products represent
                        about one third of the feed material
                        input to the ASARCO-Tacoma smelter.
                        If forced to discontinue use of these feed
                        materials. ASARCO would need to
                        compete with other copper smelting
                        companies for additional supplies of
                        copper ore. In the face of Japanese
                        competition and current copper ore
                        shortages, it is questionable whether
                        sufficient supplies of low-arsenic-
                        content copper ore concentrate could be
                        obtained at price* that would allow
                        profitable operation. More importantly.
                        the use of high-inorganic-arsenic feed
                        allows ASARCO to produce arsenic
irioxtde end metallic arsenic. EPA
estimates thai the sale of arsenic
trioxlde and metallic arsenic represents
about 10 to IS percent of the ASARCO-
Tacoma smeller's total revenue and
could account for most of the profit.
Therefore, for purposes of ihis snalysi*.
EPA is concluding thai any potential
means for limiting inorganic arsenic
emissions to the extent necessary to
significantly reduce risks would result in
closure of the ASARCO-Tacoma
  The arsenic produced by the
ASARCO-Tacoma smeller supplies
about one third of the total nationwide
demand for arsenic. The remaining two-
thirds is imported and represents over
half of the world production outside the
U.S. If ASARCO-Tacoma stopped
production of arsenic, the world arsenic
production capacity would have to
increase by 25 percent to makeup the
shortage, it is considered doubtful that
such an increase would be possible ever
with substantial upward price pressure.
The impact that this shortage would
have on industrial products-(e.g..
pressure treated lumber) and
agricultural uses (e.g.. cotton desiccanis.
herbicides) has not been estimated.

Consideration of Health Risks

  As detailed in Section I of this
preamble, the estimated health risks
cited above associated with exposure to
ambient inorganic arsenic are at best
only a very crude estimator of the actua
health effects. Thn degree of uncertainty
in these estimate is very large because
of the many assumptions and
approximations involved in their
derivation. Nevertheless, the estimated
risks due to emissions from the
ASARCO-Tacoma smelter are high
relative to other inorganic arsenic
sources and to other sources of
hazardous pollutants that have been
regulated. These levels, therefore.
provide a basis for serious question as
to whether limiting emissions based on
BAT would protect public health and
provide an ample margin of safety.
Moreover, direct ambient exposure is
not the only potential health impact
since the inorganic arsenic emitted into
the atmosphere accumulates on land
and in water resulting in other avenues
of exposure. It should be noted that
primarily due to arsenic, the
Commencement Bay Near Shore Tide
Rats area (which includes the
ASARCO-Tacoma smelter) has been
proposed as a National Priority Ust Siu
by EPA under the Superfund program
(47 FR 58478. December 30.1982).

              Federal  Register  /  Vol.  48. No. 140 / Wednesday, juty 2U. 1963 / rToposcQ nmes	******
Consideration of Impacts of Beyond
  Closure of the ASARCO-Tacoma
smelter would retult in severe social
and economic impact on the local
economy. Moreover, since the
ASARCO-Tacoma smeller-i* the only
domestic smelter capable of smelting
high-impurity copper ores and
production of associated by-products
including arsenic, closure of the smeller
would result in a total loss of this
domestic production capability. Closure
of the smeller would eliminate the jobs
of about 500 ASARCO employees and
300 additional jobs in the Tacoma area.
Closure would also mean elimination of
$20 million per year in revenues to local
companies and S2 million per year in
Slate and local taxes.

Decision and Proposed Standards
  As detailed  in Part 1 of this preamble.
under EPA's interpretation of Section
112. the smelter should be controlled at
least to the level that reflects BAT and
to a more stringent level if necessary to
prevent unreasonable  risks. The
decision as to whether the remaining
risks are unreasonable la based upon
consideration of the individual and
population risks and consideration of
the impacts, including costs, economic.
and other impacts associated with
further reduction of these risks.
  The primary purpose of standards
promulgated under Section 112 is to
protect the public health. The
Administrator is concerned that the
estimated residual risk after application
of BAT al ASARCO-Tacoma may be
treasonable, and. as  such, that
additional controls beyond BAT may be
warranted. As indicated earlier. EPA
has not identified technological controls
more efficient  than BAT: therefore, in
making a decision on an appropriate
control level of ASARCO-Tacoma. the
Administrator's consideration of beyond
BAT altemativea waa  limited to
production and arsenic throughput
limitations. These control measures
could further reduce emissions of
inorganic arsenic and associated health
risks. Arsenic  throughput for example.
could be limited to a level comparable
to a low-arsenic-lhroughput smelter
(less than 0.7 percent inorganic arsenic
in the total smelter charge), although
estimated health risks would still be
expected to be higher for ASARCO-
Tacoma than for the other smelters due
to its location  in a highly populated
  The Administrator believes that
control beyond BAT could result in
closure of the ASARCO-Tacoma
smeller. This would reduce the smelter
 contribution to the estimated health
 risks to zero: but would also result in a
 loss of fobs, a loss of domestic
 production capacity In both the copper
 and arsenic Industries, and a loss of
 revenues to local businesses and
 governments. Certainly the Impacts
 associated with closure of the smeller
 would be felt directly and immediately
 by the local population, particularly the
 employees of the smelter. With these
 potential serious negative impacts, a
 decision to require beyond BAT controls
 must be carefully considered
   Given that the calculated health risks
 estimated to remain after the application
 of BAT would be the beats for a decision
 to require beyond BAT controls and. in
 (his case, possibly cause closure of the
 ASARCO-Tacoma smelter, the
 Administrator believes it is necessary to
 scrutinise the basis for these calculated
 estimates as a part of the decision-
 making process. The estimated health
 risks were calculated by combining a
 unit risk estimate for inorganic arsenic
 with the ambient concentrations of
 inorganic arsenic predicted by modeling
 and with population data for the area
 surrounding the ASARCO-Tacoma
 smelter. As discussed in Part I of this
 preamble and Appendix B of the BiD.
 there are simplifying assumptions and
 fundamental uncertainties inherent in
 each of the components of the
 calculation, resulting in a number of
 uncertainties in the risk estimates.
   Uncertainties in the unit risk estimate
 exist due to a number of simplifying
 assumptions. Among these is the
 assumption thai a linear relationship
 exists between cancer risks and level of
 exposure and this relationship is the
 same al the low levels of public
 exposure as at the high levels of
 occupational exposure. Then is no solid
 scientific basis for any mathematical
 extrapolation model that relates
 carcinogen exposure to cancer risk at
 the extremely low concentrations that
 must be dealt with in evaluating
 environmental haxarda. Because its
 scientific basis, although limited, is the
 beat of eny of the currant mathematical
. extrapolation models, the linear
 nonthreshold model has been adopted
 here aa the primary basis for risk
 extrapolation at low levels of exposure.
 Additional assumptions made in the
 determination of the unit risk estimate
 an that all people era equally
 susceptible to cancer and that persons
 era exposed continuously from birth
 throughout their lifetimes (70 yean). The
 Administrator believes that the
 assumptions made in determining the
 unit risk estimate are reasonable for
 public health protection in that they lead
to a rough but plausible estimate of the
upper-limit of risk. That is. it is not likely
that the true unit risk would be much
more than the estimated unit risk,  but it
could be considerably lower.
  Uncertainties in the ambient
exist due to the limitations of the
dispenion model and the assumptions
and potential error in the data Input to
the model. Limitations in the model
include its inability to account for  the
variable operating conditions of the
smelter and variable meteorology: thai
is. one set of operating and
meteorological conditions was assumed
for modeling purposes. The
meteorological conditions used are
believed to be representative. However.
the smelter operating conditions used in
the modeling do not account for the
frequent curtailment of operations now
required at ASARCO-Tacoma to reduce
emissions of sulfur dioxide, and
therefore, probably result in an
overestimate of ambient air
concentrations of inorganic arsenic
(since arsenic emissions would be
reduced as well). Also, the model does
not account for sources of arsenic  other
than the ASARCO-Tacoma smelter that
an in the ana.
  In addition, then wen many inputs to
the model such as location of each
emission source at the smelter and the
rate, temperature, and height at whij
those emissions an released to I
atmosphere. Each of these input
perameten is subject to error, but
perhaps the most  crucial parameter is
the estimate of emission rates. The
emission rates used by EPA wen based
on actual emission teat data whenever
possible. However, for some sources,
most notably converter secondary
emissions, test data wren not available
at the time the estimates wen made:'
thenfon. some assumptions were made
for modeling and impact analysis
purposes. The EPA assumed, for
instance, that converter secondary
inorganic arsenic emissions were
approximately 15 percent of those
measured In the primary converter
offgases. Preliminary results of testing
conducted in f anuary 1983 on converter
No. 4 at ASARCO-Tacoma indicate that
emissions may be significantly less than
  Additional uncertainties arise from
the use of population data. The people
dealt with in the analysis an not
located by actual residence. They are
"located" in the Bureau of Census data
for 1970 (the most recent available) by
population centroids of census districts.
The effect is that  the actual locations of
residences with respect to the ettir
ambient air concentrations is not  I

Federal  Ray»ter.;|/" Vol.- :46? Nor 1*0 7 1 '• Wednesday.
                                                                             1983  /  Proposed Rules
 and the relative location! used in (he
 exposure model have changed lince ihe
 1970 census. In addition, it it atsumed
 that people remain in the ume location
 for a lifetime (70 yean). Ihe only
 exposure of the population that occurs is
 due to the ASARCO-Tacoma smeller.
 and only persons within 20 kilometers of
 the emission source an affected.
   In summary, there is a high degree of
 uncertainty in the estimated health risks
 due to Ihe many assumptions and
 uncertainties associated with the
 components of the estimates. While the
 estimated risks aay be meaningful in a
 relative sense, they should not be
 regarded as accurate representations of
 true cancer risks, furthermore, it should
 be noted that: (1) ambient monitoring
 data available for the Tacoma ares
 show significantly lower ambient
 concentrations of inorganic arsenic than
 those predicted by the model, and (2)
 data on lung cancer incidence rales for
 the ten largest cities in Washington for
 the years 1970 through 1979 show that
 Tacoma ranks filth, and the lung cancer
 rales in Tacoma are below the national
 average lung cancer rate.
  In light of the high degree of
 uncertainty in the estimated health
 risks, the apparent absence of further
 control alternatives short of closure, the
 serious negative impacts associated
 with closure, and the absence of
 comments from the affected public, the
 Administrator cannot conclude at this
 time that the risks remaining after the
 application of BAT are unreasonable.
 Therefore, standards are being proposed
 for the category of high-arsenic-
 iH»»nghpui smelters based on the
 application of BAT.
  Even though standards are proposed
 based on BAT. the Administrator
 remains concerned that the estimated
 residual health risks, although uncertain.
 are high relative to those estimated for
 other source categories regulated by
 NESHAPs as well as other sources of
 arsenic. The Administrator believes it is
 necessary to take extraordinary
 measures to ensure that his final
 determination of the central level that is
 appropriate for high-araenfc-throughpui
 copper smelters la based on the most
 complete and accurate information
 available. Therefore, the following steps
 are being taken:
  First EPA is continuing to refine its
 estimates of emissions and associated
 health risks for the ASARCO>Tacoma
 smelter. This will include a complete.
on-site emission source inventory by
 EPA personnel emission testing where
 feasible, and improved modeling. In
 particular, efforts am currently
 underway to model the effect of
ASARCO-Tacoma'a production
                        curtailment. Additionally, further
                        evaluation of controls (hat could
                        potentially be applied to reduce
                        emissions of inorganic arsenic
                        (particular/  secondary emissions) at
                        ASARCO-Tacoma will take place. This
                        evaluation will not be limited to add-on
                        control equipment but will e!so cover
                        other measures such as improved
                        operating and housekeeping practices.
                          Secondly,  a public hearing for the
                        proposed standards for high-arsenic-
                        throughput copper smelters wilt be held
                        in the Tacoma. Washington area. This
                        will give those people who would be
                        most affected by the standards the
                        opportunity to comment in person.
                          Finally. Ihe Administrator has
                        established a special task force to be
                        chaired by EPA's Region X office in
                        Seattle. Washington. The task force will
                        aid the Administrator in securing
                        available information from the area
                        which would be most pertinent in the
                        development of ihe final  standards for
                        high-arsenic-throughpul copper smellers.
                        In addition lo participating in EPA's
                        evaluation of emission sources and
                        applicable control technologies, the task
                        force will consult with experts outside
                        of EPA in the areas of health impacts
                        analysis and innnovative control
                        technologies for arsenic.
                          The Administrator is requesting
                        comments on all aspecta of the proposed
                        standards and their associated impacts.
                        Comments are also requested on other
                        control measures that may be BAT and
                        on alternatives that would reduce
                        estimated health risks more than ihe
                        alternative of applying BAT. but would
                        not result in smelter closure. These
                        comments should consider In particular.
                        the means of reducing low-level
                        secondary inorganic arsenic emisf ions.
                        which result in the highest exposure.
                        The Administrator Is also specifically
                        requesting comments on  whether the
                        estimated residual health risks
                        associated with  the BAT alternative are
                        unreasonable, considering the
                        uncertainty of these estimates and that
                        the only apparent alternative for
                        significantly reducing the risks would
                        likely result in closure of the ASARCO
                        Tacoma smelter.

                        Selection of Format of Proposed
                          Under the  authority of Section 112 of
                        the Clean Air Act. national emission
                        standards must, whenever possible, take
                        the format of a numerical emission limit.
                        Typically, an emission limit is written in
                        terms of an allowable mass emission
                        rate (mass of pollutant per unit Ume) or
                        an allowable concentration (mass of
                        pollutant per volume of gas). In some
                        instances, a process weight limit (weight
or pollutant per unit of product or
or a minimum percent emission
reduction of pollutant (control system
collection efficiency) is used. Ail of
these types of standards require (he
direct measurement of emissions to
determine compliance. As a alternative
or as a supplement lo a standard
involving direct measurement of
emissions, an emission limit may lake
the form of a restriction on opacity as
measured by EPA Reference Method 9
or on visible emissions as measured by
EPA Reference Method 22 or other
method. However, in certain instances.
numerical emission limits ere not
possible. Section 112(e)(2) recognizes
this situation by defining two conditions
when it is not feasible to prescribe or
enforce an emission limit. The
conditions are: (1) when the pollutants
cannot be emitted through a conveyance
designed and constructed to emit or
capture the pollutant: or (2) when the
application of a measurement
methodology is not practicable due to
technological or economic limitations, in
such instances. Section M2|e)(l)
authorizes design, equipment, work
practice, or operational standards.
  For the development of a standard for
the capture of secondary inorganic
arsenic emissions from converter
operations. EPA first considered
establishing a numerical  emission limit.
However, mass rate, concentration.
process weight, and percent emission
reduction formats for the capture of
secondary emissions from converter
operations are not feasible because
neither the capture efficiency nor the
quantity of emissions that escape
capture by the secondary hood system
can be measured accurately. Visible
emission data are available which
describe the performance of secondary
hood systems over a limited range of
operating conditions. However, these
data are not considered to represent a
sufficient basis for establishing emission
standards which must be achieved at all
times. Therefore, the format selected  for
the proposed standards for the capture
of secondary inorganic arsenic
emissions from converter operations is
one in which equipment and work
practices are specified.
  For the development of a standard  for
the collection of secondary inorganic
arsenic emissions from converter
operations. EPA concluded a numerical
emission limit Is feasible. EPA first
considered developing an emission limit
specifically for inorganic arsenic.
Inorganic arsenic emissions from
converter operations vary in relation  to
the inorganic arsenic content of the ore
concentrate processed. Smelting a high-

                                             i\o. nu  /  weanesday. |uly 20. 1983 / Proposed Rules
 mnrganic-arseniC'COntent ore
 concentrate has the potential for higher
 inorganic arsenic emissions than a low-
 ccmcentrate. The ASARCO-Tacoma
 smelter is a custom smelter processing
 ore concentrates shipped fl0m domestic
 and foreign copper mines. An
 interruption or discontinuation in
 shipments from one supplier could
 change the average inorganic arsenic
 content of the total smelter charge
 processed at the ASARCO-Tacoma
 smeller. Thus, the future inorganic
 arsenic content of secondary emissions
 from the ASARCO-Tacoma smelter may
 increase or decrease depending on the
 mix of suppliers selling ore concentrate
   The potential variability  in the
 inorganic arsenic content of secondary •
 emissions from the ASARCO-Tacoma
 smelter increases the complexity of
 developing numerical emission limits
 specifically for inorganic arsenic.
 F.mission limits frr inorganic arsenic
 based on a mass emission rale, process
 weight, or concentration format would
 establish an upper limit on  inorganic
 arsenic emissions only. An inorganic
 arsenic emission limit based on the BAT
 emission control requirements
 specifically for the ASARCO-Tacoma
 smelter based on currant data might not
 require application of BAT la other ore
 concentrates were processed. In
 contrast, n percent reduction format
 would require the application of BAT
 regardless of the level of inorganic
* arsenic content in the feed materials.
 However, high collection efficiency may
 not oe continuously achievable for the
 entire range of inorganic arsenic
 concentrations which could occur in the
 captured gas streams from the
 secondary emission sources.
   As an alternative, an emission limit
 for total particulates that reflects the
 level of control device performance
 necessary to achieve BAT for collection
 of secondary inorganic arsenic
 omissions can be developed. There are
 several advantagea lo using a total
 paniculate emission limit to regulate
 inorganic arsenic emissions. First, total
 paniculate emissions from primary
 copper smelter operations remain
 relatively content regardless of the •
 inorganic arsenic content of the ore
 concentrate. Thus, a total paniculate
 emission limit would require the uae of
 BAT for all high-arsenic ore
 concentrates regardless of variations in
 the inorganic arsenic content of the feed.
 The second advantage  to •  total
 paniculate emission limit Is that EPA
 Reference Method 5 can be used to
 determine compliance.  This method is
 widely used: and because it captures
 larger quantities of participates, it offers
 the potential for greater precision.
 Therefore, for these reasons EPA
 decided to develop standards for
 collection of inorganic arsenic emissions
 based on a total paniculate emission
  Muss emission rate, percent emission
 reduction, process weight rate, and
 concentration formats were considered
 by EPA for setting emission limits for
 the collection of captured secondary
 emission gas streams. All four of these
 formats provide viable alternatives for
 setting total paniculate emission limits.
  A mass  rate format would limit total
 paniculate emissions per unit of time.
 However,  this format would not reflect
 differences in production rates (e.g..
 amount of ore concentrate, calcine, and
 matte processed). The mass emission
 rate standard would only place an upper
 limit on the total amount of particulars
 emitted per hour or per day.
  A percent reduction format would
 specify a minimum percent reduction of
 total paniculate emissions across a
 control device. Determination of
 compliance with a percent reduction
 standard requires measurement of both
 uncontrolled and controlled emissions.
The measurement of emissions at the
 inlet :o control devices poses leafing
difficulties due lo ductwork and control
device configurations. The ductwork
modifications necessary to perform
accurate inlet testing at the ASARCO-
Tacoma smelter would significantly
increase the cost of the compliance
  A mass per unit production format
would limit total paniculate emissions
per unit of copper produced or smelter
charge. Determination of compliance
with a mass per production unit
standard requires the development of a
material balance or production values
concerning the operation of the copper
smelter. Development of thia
information depends on the availability
 and reliability of process data provided
 by the company. Gathering these data
 increases the testing and rtcordkeeping
 requirements and. consequently.
 increases the compliance determination
  A concentration format would limit
total paniculate emissions per unit
volume of exhaust gases discharged to
the atmosphere. Compliance
determination of concentration
standards  requires • minimum of data
and Information, decreasing the costa of
 testing and reducing chances of
measurement errors. Furthermore.
 vendors of paniculate control devices
usually guarantee equipment
 performance in terms of pollutant
 concentration in the discharge gas
 stream. There is a potential for
 circumventing a concentration standard
 by diluting the exhaust gases diicha
 to the atmosphere with excess air.
 lowering the concentration of total
 particulates emitted but not the total
 mass emitted. However, for this
 application, this problem can be solved
 by specifying a measurement location.
Therefore, because a concentration
 format would involve tower resource
requirements and a less complicated
compliance determination procedure
 than the other formats. EPA selected a
concentration format as the most
suitable format for the proposed
standards for collection of secondary
St'/rftitin of \'um#rial Emission Limit
tinti Kquipmrrnt Spt>rifications

  The proposed standards are based
upon the application of a secondary
hood system to capture convener
secondary emissions and a baghouse or
equivalent paniculate control device to
collect the captured secondaty
emissions from conveners.
  The format selected for the proposed
standard for capture of secondary
inorganic menic emissions from
converters consists of equipment and
work practice specifications. EPA
believes thai the prototype secon
hood design installed on converter N
at the ASARCO-Tacoma smelter is
capable of achieving a capture
efficiency level consistent with BAT if
the system is installed and operated
properly. Therefore, the design and
operation of this system were the basis
for the equipment and work practice
  The principal components of the
secondary hood system are a hood
enclosure, an air curtain plenum and
exhaust hood. fans, and sufficient
ductwork to convey the captured
emissions to a control device. Because
each secondary hood system must be
custom designed due to variations in
converter configuration and space
availability. EPA chose not to specify
physical dimensions for the hood
enclosure. Instead. EPA decided to
specify the design practices that are
necessary to follow in order to obtain a
secondary hood system capable of
achieving at least a 95 percent capture
efficiency. These design practices are:
(t) the configuration and dimensions of
the hood enclosure an slxed so thai the
converter mouth, charging ladles.
skimming ladles, and other material
 transfer vessels are housed within the
confines or influence of the hood dun

F«dcni  Refistar  /
     NoTWV  Wednesday. '[ulyJO.  1983 / Proposed Rules
each mode of converter operation: (2) "•'
the back of the hood enclosure Is hilly
endoMd and waled against the primary
hood: (3) the ed|«s of the hood enclosure
side walls in contact with the convener
   •ael remain sealed during each mode
 .  inverter operation: (4) the size of the
opening at the top and front of the hood
enclosure necessary for the entry and
egress of ladles and crane apparatus is
minimised to the fullest extent practical:
•nd (5) the hood enclosure is fabricated
in  such a manner and of materials of
sufficient strength to withstand
incidental contact with ladles and crane
apparatus with no damage.
  The air curtain is produced by
blowing compressed air from a narrow
horizontal slot extending the length of a
plenum along the top of one side wall of
the hood enclosure. The dimensions of
this slot and the velocity of the eir
blown through the slot are essential
design parameters for determining the
momentum of the air curtain. Sufficient
sir curtain moBenlum must be
maintained to prevent emissions rising
from the converter operations inside the
hood enclosure from penetrating the air
curtain and escaping to the ambient air.
  To ensure that the owner or operator
has the capability  of developing
sufficient momentum in the air curtain to
capture secondary emissions, the
proposed standards specify that the air
curtain fan be sized to deliver a
minimum of 2L37Q waits (30 air
horsepower) at the slot
  After installation of an air curtain
secondary hood system, the owner or
operator would be required to operate it
si  conditions optimum for the capture of
secondary inorganic arsenic emission!
(see "Optimization of Secondary Hood
Air Curtain System")- In addition, the
owner or operator would be required to
visually inspect the components of the
system at least once every month and
maintain each converter and associated
secondary hood system in a manner
consistent with minimizing inorganic
arsenic emissions-
  Over a 1-week period. EPA personnel
observed the ASARCO prototype
secondary hood system during all
converter operating modes. Based on
these observations, EPA concluded that
the wort practices followed by the
individual converter and crane
operators can significantly impact the
amount of secondary emissions that are
captured by the secondary hood system.
To assure tile maximum capture of
secondary emissions, the Administrator
is  proposing five work practices to be
followed by the converter and crane
operators. These work practices are (1)
sii curtain and exhaust flow rates shall
br increased by the converter operator
to optimum conditions prior to raising
the primary hood and roiling the
convener out for skimming: (2) once
rolled out. the convener operator shall
hold the converter in an idle position
until fuming from the molten bath ceases
prior to commencing skimming: (3)
during skimming, the crane operator
shall raise the receiving ladle off the
ground and position the ladle as close as
possible to the convener to minimize the
drop distance between the convener
mouth and receiving iadlr. (4) the rate of
(low into the receiving ladle shall be
controlled by the'converter operator to
the extent practicable to mimimize
fuming: and (S) upon completion of a
charge, the crane operator shall
withdraw the charging ladle from (he
confines of the hood enclosure in a slow
and deliberate manner.
  The Administrator believes that it
may be appropriate to specify minimum
time periods to be associated with some
of these work practices, such as with (1).
(2). snd (4) above. The public is invited
to comment on the need to specify
minimum times to be associated with
ihe proposed work practice standards
am on what limes may be appropriate.
  ASARCO has staled it intends to
install air curtain secondary hood
systems (similar to the system already
in place on converter No. 4) on its
conveners that will remain in service at
the Tacoma smelter. EPA therefore
expects that ASARCO would meet
NESHAP requirements for controlling
secondary Inorganic arsenic emissions
from converters at Tacoma by installing
air curtain secondary hood systems.
However, the proposed equipment
specification is not intended to preclude
the use of other secondary inorganic
arsenic capture systems which may be
as effective as an air curtain secondary
hood. Upon written application to EPA.
the use of an alternative secondary
inorganic arsenic capture system which
has been demonstrated to EPA'r
satisfaction to be equivalent in terms of
capture efficiency for inorganic arsenic
may be approved (see "Equivalent
Systems for the Captum of Secondary
Emissions from Converter Operatx .is"
in Pan 111 of this preamble).
  To reflect the level of control device
performance necessary to achieve BAT
for collection of secondary inorganic
arsenic emissions. EPA selected a
format specifying • maximum allowable
total paniculate emissions limit For
selecting the numerical value of the
limit EPA reviewed the paniculate
emission source test results for the
control devices Judged to represent BAT.
The lest results were discussed in the
Control Technology section of this pan
of the preamble. These results consist of
                                                               a series of three consecutive sampie
                                                               runs for which the measured total
                                                               paniculate matter emissions at the
                                                               control device outlet ranged from 1.1
                                                               11.6 mg/dscm. The average value for
                                                               three runs was S.1 mg/dscm. The res
                                                               show that a control level of at least 1
                                                               mg/dscm can be achieved: and. most
                                                               likely, control devices will achieve
                                                               significantly lower emission levels.
                                                               Therefore. EPA selected 11.6 mg/dsc
                                                               as the proposed emission limit.

                                                               Selection of Emission Test Methods

                                                                 The use of EPA Reference Method
                                                               "Determination of Paniculate Emissi
                                                               from Stationary Sources" tn Appendt
                                                               of 40 CFR Part 60 would be required
                                                               determine compliance with ihe
                                                               concentration standard for total
                                                               paniculate matter emissions.
                                                               Calculations applicable under Metho
                                                               necessitate the use of data obtained
                                                               from three other EPA test methods
                                                               conducted before the performance of
                                                               Method S. Method 1—"Sample and
                                                               Velocity Traverse for Stationary
                                                               Sources" must be conducted in order
                                                               obtain representative measurement
                                                               pollutant emissions. The average gas
                                                               velocity in the exhaust stack is
                                                               measured by conducting Method 2—
                                                               "Determination of Stack Cas Veiocrr
                                                               and Volumetric Flow Rate—{Type S
                                                               Pilot Tube).** The analysis of gas
                                                               composition is measured by conduct:
                                                               Method 3— "Gas Analysis for Carbo
                                                               Dioxide. Oxygen. Excess Air and Dr>
                                                               Molecular Weight" These three test;
                                                               provide data necessary in Method S '
                                                               converting volumetric flow rate to m
                                                               flow rate. In addition. Method 4—
                                                               "Determination of Moisture Content
                                                               Stack Cases" is suggested as an
                                                               accurate mode of predetermination c
                                                               moisture content
                                                               Selection of Monitoring Requitvtnen

                                                                 Section 114 of the Clean Air Act
                                                               authorizes EPA to establish monitor
                                                               requirements for the purpose of
                                                               determining violations of standards
                                                               proposed under the Clean Air Act. A
                                                               monitoring data must be maintained
                                                               such a manner so as to be accessible
                                                                 The performance of the equipment
                                                               used to capture the secondary emiss
                                                               from the coverter operations is highl*
                                                               dependent  on flow rate. If the flow r
                                                               is not measured, it is not possible fo:
                                                               either the operator or EPA to determ
                                                               whether the equipment is properly
                                                               operated and maintained. Therefore
                                                               proposed standards require continue
                                                               monitoring of the time and air flow r
                                                               through the eir curtain systems, and
                                                               keeping a log of times for each of tht

                     lesoay. jtuy
                                                                             i»cu /  troosea
 convener open lions. This would allow
 (he correlation of recorded gas flow
 rites with th* corresponding convener
  To help the Administrator determine
 whether each secondary hood system is
 being properly operau.il and maintained.
 measured airflow rates would be
 compared to source specific reference
 values established during the
 optimization of each system for each
 converter operating mode. (See
 "Optimisation of Secondary Hood
 System".) To establish source specific
 airflow reference values, the owner or
 operator would determine the flow rates
 that correspond to each converter
 operating mode while the secondary
 hood system is operating under optimum
  The proposed standards for the
 collection of secondary inorganic
 arsenic emissions are based upon a total
 paniculate concentration limit. One
 alternative to monitoring the
 performance of the collection device is
 10 periodically lest the collection device
 using Method S. However, this
 alternative is cosUy and is not
 considered reasonable. Continuous
 monitoring of opacity or an operating
 parameter of the collection device may
 be used to indirectly monitor
 performance by indicating whether or
 not ihe collection device is operating in
 the same manner as when it
 demonstrated compliance during the
 emission test. Of these two alternatives.
 monitoring opacity is simpler to apply.
 Therefore, the monitoring requirement
 selected for the collection of secondary
 fc......lie emissions is to continuously
 monitor opacity using a
  To implement this monitoring
 requirement it would be necessary to
 establish a reference opacity level
 against which future performance of the
 control system could be compared. To
 establish the source specific reference
 opacity level the owner or operator of
 the source would be required to conduct
 continuous opacity monitoring during
 the emission teat. The opacity
 monitoring results would be reduced to
 6-minute averages, and die opacity level
 would be established at the 97-9 percent
 upper confidence level of a normal or
 log normal (whichever is more
 representative) distribution of the 6-
 minute average opacity values. This
 opacity value would be the basis for
 determining whether the collection
 device is continuously performing
effectively. Any monitored opacity
reading above the emission test opacity
reading would indicate that the
collection device may no longer be
meeting the proposed total paniculate
emission limit. A Method S test could
then be performed to determine

Optimization Of Air Curtain Secondary
Hood System
  It is intended that the installation-of
equipment specified in the proposed
standards for the capture of converter
secondary emissions will give the owner
or operator of each affected converter
the capability of reducing emissions to a
level consistent with the application of
BAT. In developing the equipment
specifications, the Administrator has
been specific for some requirements es
in the case of fan horsepower capacity,
and more general for others, such as the
dimensions of the secondary hood.
Some of Ihe requirements are general
because unless then are any new
smelters, which Is considered unlikely.
each installation will be a retrofit: that
is. each air curtain secondary hood
system will have to be custom designed
to fit each existing converter. Due to
space limitations, existing pollution
control equipment already in place and
other considerations, the exact
configuration of each secondary hood
with air curtain system installed  will
vary from smelter to smeller.
  Beyond hood configuration, the
performance of each air curtain
secondary hood system will depend on a
balance of several other parameters.
including the dimensions of the air
curtain slot the velocity of air through
the slot and the distance from the slot
to the offtake. These parameters  an
adjustable in the sense that they  can be
altered in a relatively short time and at
relatively small cost ft is expected that
after the initial Installation of each air
curtain secondary hood system, then
will be a "shakedown" or optimization
period during which the proper balance
of system parameters will be determined
for each particular Installation.
  For every air curtain secondary hood
installation, there will be an optimum
set of operating conditions, beyond
which further "fine tuning" of the system
will not result In increased capture
efficiency. Section 112(e)(l) of the dean
Air Act slates; in part that If the
Administrator promulgates a design or
equipment standard, "ha shall include as
part of such standard such requirements
as will  assure the proper operation and
maintenance of any such element of
design or equipment" "Proper
operation" of aa air curtain secondary
hood system includes operating the
system aa dose to optimum conditions
as possible, and the owner or operator
would be required to do so under the
proposed standards. It fs not the
Administrator's intent however, to
require the owner or operator to operate
a system beyond optimum conditions
(i.e.. at flow rates and power
requirements that do not achieve ^mv
additional capture) or to prevent ^B
operational changes that may not URt
the capture efficiency of the system.
  Authority for determinatioo of the
optimum conditions for each air curtain
secondary hood system installed to meet
the proposed standards would real with
the Administrator. Out to the variables
involved, and the fact each Installation
will be site specific, it la not possible for
the Administrator to prescribe in
advance what will constitute optimum
operating conditions for each air curtain
secondary hood installation. Objective
techniques, such as the tracer study
used to evaluate the air curtain
secondary hood system on Ihe No. 4
converter el the ASARCXXTacoma
smelter, an available to help determine
capture efficiency. However, a final
determination of whether a system has
truly been optimised, or if not what
steps should (or could) be taken to
improve it will largely be a matter of
  One approach the Administrator is
considering as a method for determining
optimum Renditions for each air curtain
secondary hood installation would be to
have each system evaluated by a panel
of persons with expertise in i
visible emissions of air pollutants.'
panel could be comprised of 3 or i
persons, including representatives of
industry. EPA and local air pollution
control agencies.
  The panel would evaluate each air
curtain secondary hood as follows:  (1)
the panel would review tot plans and
specifications of the system prior to
installation: (2) the panel would agree
on initial operating conditions for the
system; (3) the penal would observe the
operation of the system during each
mode of converter operation under the
initial operating conditions. Estimates of
the capture effectiveoeaa achieved.
based on visual observations, would be
recorded by each panel member for
each mode of operation. In addition.
comments on the minimum and
maximum capture effectiveness
achieved, the duration, location and
density of visible emissions observed.
end a qualitative assessment of the
volume of the emissions escaping
capture (e.g, light moderate, heavy,
etc.) would be recorded: (4r based on
this initial evaluation, the panel would
agree on what modifications would be
needed to further optimize the operation
of the air curtain secondary hood: i
(S) the panel would again view the

                              if-SW      Vsftf**    " •-•««'•&       |fijS$      -'%$t
               Federal Raytter."/'Vol. 48.  No. 140  / Wednesday. |uly'2Q. 1963 / Proposed Rules
 system (•• la 3) tfitr modification to
 compart its performance to ore-
 modification performance. Alter this.
 •ttpa 4 and S would be repeated ai
 needed until there wes agreement
 amenf ">• panel member* that the
 system had been optimized. The panel
 would then recommend a set of optimum
 operating condition* for thai lyitem to
 the Administrator alon| with  •
 documentation of their evaluation. In the
 event of dispute*, panel member* would
 •ubmit aeparate recommendations. The
 Administrator would make a final
 determination of the optimum conditions
 based en the panel's recommendation
 and supporting documentation.
  If. subsequent to a determination thai
 a system has been optimised, an owner
 of operator proposes to make an
 additional modification to the system.
 the panel would again  be convened and
 would observe the system both before
 and after the change as prescribed in (3)
 above. The modification could be
 approved by the Administrator if the
 panel found It did not reduce capture
  The Administrator believes this
 approach would assure that the air
curtain secondary hood system is
designed and operating conditions
established which will  minimise
secondary inorganic arsenic emissions
to the greatest extent possible, but
would also allow the owner or operator
to make modifications  to the system that
would not reduce capture efficiency.
The public is invited to comment on the
need to evaluate the optimization of
each air curtain secondary hood system
 •«4 on the panel approach being
considered by the Administrator.

Reporting and Recordkeepiny
  Owners or operators of sources
covered by the proposed standards
would be subject to the reporting and
recordkeeping requirements of the
proposed standards, as well as those
prescribed in the General Provisions
(Subpart A) of 40 CFR Part 61. Under
 I «UO of the General Provisions, an
initial report from each existing source
Is required to be submitted within 90
days of the effective date. For purposes
of determining Initial applicability, the
proposed standards for high-arsenic-
 throughput smelters specify that the
 initial report required in I 61.10(a) will
 include information en the weight
 percent inorganic arsenic in the total
 smelter charge. The proposed standards
 further require that each month the
 computation of a rolling annual  average
of the inorganic arsenic content of the
total smelter charge be made and that
the  monthly computation of a rolling
                                       annual average of the inorganic anemic
                                       content of the total smelter charge be
                                       made and that the monthly
                                       computations be recorded and dept on
                                       site for at least 2 years; The monthly
                                       computations would have to be reported
                                       to EPA on an annual basis to ensure thai
                                       applicability with respect to  the
                                       standards had not changed.
                                        Under Section 114. EPA is  authorized
                                       lo establish reporting requirements to
                                       determine whether there is a violation of
                                       standards proposed under the Clean Air
                                       Act. Concern as to whether the systems
                                       for the control of inorganic arsenic
                                       emissions are continuing to meet the
                                       proposed  standards would primarily
                                       arise when monitoring showed opacity
                                       levels in excess of those determined
                                       during the compliance demonstration or
                                       airflow rates that vary significantly from
                                       those established during the
                                       optimization procedure. Therefore, in
                                       determining the necessary reporting
                                       requirement*, it was considered.
                                       reasonable to require reporting only
                                       when such "excess emission" conditions
                                       exist Reporting of these excess
                                       emission conditions would be required
                                       on a semiannual basis. Currently, only
                                       the copper smelting companies collect
                                       any of this information. In addition.
                                       there are no reporting requirements by
                                       other governmental agencies for this
                                       type if informstion which would result
                                       in overlapping data requirements. The
                                       types of information to be included In
                                       the reports are discussed below.
                                        r or the converter secondary hood
                                       system, each semiannual report would
                                       indicate: (1) the reference airflow rates
                                       established for each converter
                                       operational mode, and (2) a record of
                                       airflow rates for each day when the
                                       airflow rates are leaa than 20 percent of
                                       the corresponding reference values.
                                        For the  collection devices for
                                       secondary emissions, each semiannual
                                       report would provide: (1) a record of
                                       transmisaometer readings for each day
                                       on which  the opacity exceeded the
                                       reference  opacity Unit determined et the
                                       time the collection device demonstrated
                                       compliance, and (2) the values of the
                                       emission lest opacity limits.
                                       Impact* of Reporting tad Recordkeeping
                                        EPA believes that these reporting and
                                      reeordkeeping requirements are
                                      necessary to assist the Agency In (t)
                                      identifying sources. (2) observing the
                                      compliance testing and demonstration of
                                      monitoring devices. (3) determining
                                      initial compliance, and (4) enforcing the
                                      standard after the Initial compliance
                                        The Paperwork Reduction Act (PRA)
                                      v.   O(Pub. L 96-911) requires that the
Office of Management and Budget
(OMB) approve reporting and
recordkeeping requirements thai qualify
as an "information collection request'.'
(ICR). For the purposes of
accommodating OMB's review. EPA
uses 2-year periods in its impact
analysis procedures for estimating the
labor-hour burden of reporting and
recordkeeping requirements.
  The average annual burden on high-
arsenic-throughput copper smelters to
comply with the reporting and
recordkeeping requirements of the
proposed stsndards over the first 2
years after the effective date is
estimated to be 1J10 person-hours.

Regulatory Flexibility Analytic

  The Regulatory Flexibility Act of 1960
(RFA) requires that dlfferentisl Impact*
of Federal regulation* upon small
businesses be Identified and analyzed.
The RFA stipulate* thai an analysts is
required if e substantial number of small
businesses will experience significant
impacts. Both measures must be met:
that is, a substantial number of smalt
businesses must be affected and they
must experience significant Impacts, to
require an analysis. Twenty percent or
more of the small businesses in an
affected industry is considered a
substantial number. The EPA definition
of significant impact involves three
tests, as follows: (1) prices of products
produced by small entities rise I percent
or more, assuming costs are passed on
to consumers: (2) annuaiized investment
costs for pollution control are greater
than 20 percent of total capital spending:
or (3) costs as a percent of sales for
small entities are 10 percent greater than
costs as a percent  of sales for large
  The Small Business Administration
(SBA) definition of a small business for
Standard Industrial Classification (SIC)
Code 3331. Primary Smelting and
Refining of Copper. Is 1.000 employee*.
The ASARCO-Tecome smelter is owned
by a company that has more than 1.000
employees. Therefore ASARCO does
not meet the SBA definition of a small
business and tints no regulatory
flexibility analysis Is required.




A-14 Tacoma, Sun.. July 17, 1983, The News Tribune

Smelter    battle
   Politics,  economics and environmental  issues
   are  whirling  around the Asarco controversy
      «t me try to dance a few an-
        gels on tb* head of a pin."
  began beleaguered Environmental
  Protection  Agency northwest ad-
  ministrator Eroesta Bane*.
    She was  trying to answer yet
  aeottar difficult question  about
  tlie danger* poaed by Asarco ar-
  senic to ana residena.
    Much about this novel contro-
  versy — in  which the federal gov-
  ernment has asked a community
  to help decide how ffr^ of a can*
  cer risk it wants to assume — ha*
  that ring aboot it of the medieval
  aigunient over the mmher of an-
  gels that eeoid pirouette on a pin-
    Tte EPA has proposed regula-
  tions that wonM require Asarco to
  spend M J million to intail i
  air poUittioh equipment. Bat the
  EPA also has told citttens the air
  pollution equipment is not expect*

  from  the Boston smelter.  The
  EPA says that'for all it knows,
  any amount of arsenic is harmful
  to health.
   The eqaipmeat will rednce only
  low-level (not emitted from the

  from 310 tons per year to 119 tons
  per year, EPA •"•ftp*"-'  Asarco
  said it doesn't know where EPA
  got those numbers.
   The federal  agency also has
  gone out on a •^•»iff>«|"> jimK ^p^
  predicted that  instead of losing
  four persons per year to hog can-
  cer as the area ostensibly dees at'
  present, the new control equip-
  ment would mean only one long
  cancer death a year. Asarco, on
  the other hand, claims its arsenic
  emissions are safe  for human,
  and the EPA  has admitted its
  mathematics for its cancer death
  statistical model may be wrong.
    Banes explained the  cancer
  statistical model tries to account
  for such variables as weather and
  emission data and the poorly un-
  derstood relationship of arsenic to
  cancer in humans. The model as-
  sumes a person lives to the area
                          • It's time for Taco-
                          ma to change its im-
                          age,  instead  of
                          covering  for   these
                          guys  like Asarco,  it
                          should try to bring in
                          new industries,
fern years, a

people move in and out, take va-
            for the SPA, said
tM MftUCf Isl 801 COOfBMd by All
s*lhek, •BeeeBmh^htat* fc^M^k^ Ank^^^t^*^ • _—•_ j
IB*V IMIIIIMN OuflDg] taVvwsl •••"•Mf
         tfetftM lai gwkaejtda HaMujarifta
             avsea as there-
             lie to cancer. He
said the agency is attempting to
"stmpUfy" the issue for the public.
  Beyond the issue of which, if

the bigger question of how """"^

  The question is, Is lt9 tons lit-
tle enough to eonstitate aa ample
margia of safety for the public in
the vicatty of or downwind of the
smeiterr " Banes said last week,
  It isn't an issue the EPA even
wanted 10 face, at least not yet.
  "EPA dWat come forward with
     votviag arsenic being blown from
     New Jersey to Staten Island.
       But now that issue is being ad-
     dressed, what a time Tacoma is in
       Last week. Rotten and Tacoma
     made newt on the front page of
     Tb» Mnr Kant Hme* and on na-
     tional televisioa. Reporters from
     major newspapers around the
     country are coming to Tacoma.
       Orgaaiaed groups are marshal-
     ing their forces for aa Aug. 30
     showdown before aa EPA board in
     the Bicentennial Pavilion.
       EPA  Administrator  William
     Ruckelsaaus is expected to review
     the record of the Aug. M public

     decision on •• ETifflfc standard in
(an arsenic) standard
the oomDiexjt? of the
complexity simply oven
the statt. We would have gotten
then eventually," Banes told TU«
/V*wt Trioune editorial board.
  As it is, the anenje problem in
Tacema is being faced because of
the order of a federal Judge sitting
in New York dectdin* * -—- •-
tioos at the smelter by
mental groups. If history is
instructive, expect another major
public relations and technical ex-
travaganza by Asarco of the kind
it prepared for a variance hearing
before the Puget Sound Air Pollu-
tion Control Agency in 1981.
  "I expect we will be there and
will testify. To what extent. I am
not certain." said Larry Liadquist,
smelter manager.

    (Continued on next page)

A-14 Tacoma, Sua, July 17,  1983, The News Tribune

Smelter    battle
 (Continued from

                        a«    * '  h°Pe jt wjl! be decided on the scientific
                             merits  of  the  case-   '   think  emotional
    present to the EPA.          appeals will  be made,  based on emotion

    t in the put. tb* theme, t«t.   alone. This  is  inevitable  in 'something like
      tressed by testimony from   ...
doctor* and university research-   mlS. •
en. is expected to be that smelter         +     •                                   -
emission do not hum people At                                         — <-^ry Undquiet
the 1981 variant* bearing, Asaree                                    A*areo anMitar manager
hind the Seattle public relations
f inn of Hill ud Koowitea to I
die publicity.                  mented. *1 an cooceraed about   about" calling for a shotting down
  Additionally. Asareo is likely w  the way in which public opinion a   of the metier.
emphasize the good toe smelter  soaped often by the party with the     "I don't believe anyone is seek-
does in the ana. It employs some  greatest amount of money."        ing total danre of the milL" said
570 people, has a multi-miiUoe    Earifouuietttalisti  don't  have   Deag Jackman. of the Washington
payroll, pays taxes aad makes  the money the industrial giants   Long Association.
large purchases on the local mar*  caatapvbesaid. What money they     Baird said,"W» will  stand for
ket.                 •       "senpe" together i§ diffused late   very right health pfoteetioa. snd it
  Tte* an seme mare exotic  annmber of issaes. sach at are*   does  not appear  Asareo will be

mamrfaetarer of ansase to  the    BaM said the eaTtraamentalist     "IfstiiBeforTacomatoehanfe
'Tnited States.                 will try tocoanter Asarco'sflaaa-   its image. Instead of cowriag lor
  Pesticide  manofaetarers  and  dal might by fbrmmi fiMBttMi   tBIM l°7* Uk* Asareo, it should
-then who ose arseaic in their  with groope lite  ueVasaiaitoa   try to bring in new  iadastries to
prodocts would incur higher casts  Long  Associatloa aad othen to   take the place of the polluters.
if they had to purchase the metal  "inform the pahtte and itt oroner     "^e want Taeomt to  be abte to
in foreign countries which don't  repnseatatiaaatme bearing.''     employ people withoat killing peo-
have to pay for expensive poiln-    "We may have demonstrations   P***"
uon controls. Lindqunt said.       to highlight the tasae." Baird said.     Baird also tBtnsted, that  the
  BriaaBairCametBbarofTahe-    Be  addaa the enrUoumeatai   smelter aad the pabUctty it has
ma«for * Healthy Enrtnameat  conmwmty wjfl ate he nmewmg   been reeatviBf could  hart coovw-
(THEX said he a already worried  arsenic and EPA cafrra* benefit   tioq and
about the kind of campaign A*ar-   sadiesita pnpan fortbt beanag.   the city hopes the Tacoma Dome
co may wage.                   Tbo EPA to expected to provide   wiflatttact
  "Tacoma is setttag a precedent   Off* boxes fwitamtog stadias aad     Conversely. Baird said his or*
(inEPApoUcy)aodttisa«tecea.   other data on the issae to the Ta-   naization doesn't want the word
ceivahle- Asareo would launch a   coma  Pahtte Lihrary so residents   togo out  that Tacoma resideao
publicity campaign, and pubUebe   can prepan for the bearing, ac-   an willlnc to take risks with their
distorting  facts or information   cardiac to Bob Jaeebsoa. a   healUL^   '\-
that suits their desires .. „" said   spokesman for the EPA,            ^f every company leans Taco-
  uT^ut k. « --      .». . .v-    Another tactic of the environ*  mans an willing to die for env
  He said be is concerned that the   ^^i «-™,™,^ approach la-  ptoyment. the the aggregate effect
                                                IB ally,  can be unacoepualy large," he
                             --„,-,-..,.  „,„.»,.,	trjT-riT of the  said.
     than a health and scientific   United Sleelworkcn of America.    Baird also hopes national dean-
                             have  traditionally  stood solidly  air groups will become involved in
                             heated the smelter management  theTi
   Liadquist. the smelter man**   on the environmental issaes. The
     ger. has a similar concern.    smeltermen have been supported
  UI hope it will be decided on the   in the past by some other
  He said smelter employees have     An effort likely will be made to
already heard one person call a   eonvtoce labor leaden  that "the
radio talk show aad complain it   net effect of pollution controls is
                Asareo  was   thecnatiOB of JOBS." Baird said.      Continued On Page A-15
  ,i_  -   -                       Perhaps in an effort to recruit    ^^
  On  the other side. Bain* ram.   alliwi

Tacoma, Sun., July 17, 1983, The News Tribune
From Page A-14
  Friends of the Earth, guessed that
  environmental expert* won't  be
  brought in from  New  York and
  Washington. D.C. to unify in Ta-
    He said Rackeishaus' proposal
  that tte public help define the ar-
  senic risk it will accept is a "trial
  ^llflAfi that b*t already burst."
    Jones said that if Ruekelshaas'
  decision was in any way based on-
  a "public opinion poll it wouldn't
  stand op in the coons."
    Barnes, the rational EPA ad-
  ministrator in  Seattle, has  said
  public  input will be "extremely
  important" in the decision-making
    Jones said that if RackeishsBS'
  proposal was valid, it would mean
  that people in the industrial Ohio
  Valley would be helpinf to make
  decisions about acid rain caused
  by >tH>tr tmtiit>i"fl plants that falls
  in New Rutland
    Tte  law  requires that tte deci-
  sion be based on the EPA'spnmd-
  ing a "margin of (public) safety."
  be said.
    "If  (Hncktlahaos) wants to
  ctengv tte law. he has to go to
  Congress,"  Jones said.
    Otter  groups art also warning
  that tte EPA must be careful of
  the grounds on which it makes its
  decision on Aaareo's tmiitinm
     "Tte Clean Air Act does not in*
  elude cost as a criterion for devel-
  opment  of  hazardous   air
  pollutants  (controls)," said Jack*
  man, of tte Washington Loaf As-
    Ruth Weiner, chairwoman of
  tte Cascades Chapter of tte Siena
  Club,  said she  thought Rack*
  dsbaus was attempting to make it
  1 an environment-vss sus»jobs is-
  sue" without really trying to ex-
  plore  what  new  technology  is
  available to  control tte arsenic
  emissions and allow tte plant to
  stay open.
    But  Joe Stortini. tte Pierce
  County councilman who sits on tte
  Puget Sound Air Pollution Control
  Board, said be thinks it is "super"
  that tte federal government is
  asking local  residents what they
     Some  groups have not decided
  what to do.
     Arthur Oanunkoehler. air pollu-
   tion control officer for the Puget
   Sound Air Pollution Control Agen-
   cy, said that  agency  first has to
   evaluate the EPA oroopsaland its
                back-up information.
                  He said the PSAPCA board is
                scheduled to vote on its formal po-
                sition at its Aug. 11 meeting.
                  Stortini said be hopes the PSAP-
                CA board will vet* to continue its
                position of requiring tte air pollu-
                tion en^pment to be installed. Tte
                proposed EPA position is an en- ;
                dorsement  of tte PSAPCA order
                issued in 1911.
                  Tte League of Women Voter* is
                expected to develop its  position on

                cording to a league spokeswoman.
                   White arsenic has beta attract-
                 ing all tte  attention  this week.
                 otter smelter-related  issues are
                 Awaiting their turns.
                   For exampiat
                  • Tte EPA, state Department
                 of  Ecology  and Tn iinia Flfne
                 County Health Department an at-
                 tempting to  deal  with a  wide
                 range of pollation issues that are
                 affecting tte land, ground water

                                'Bay  ana  has-
                                •  OB* of tte 1ft
     would  have to "sacrifice"
     erson a year to ananio-ia-
duced lung cancer if tte EPA pro-
posal is endorsed by Rockatsbaus.
  "We must  add ... their sulfur
diosid*. plus cadmium and lead.
That one arsenic death excludes
everything else Asarco puts out."
  Ironically, economics may re-
solve tte smelter tssoe.
        entire copper  twlusuj is
 not doing well < financially," said
 Uadquist Be claimed that while
 tte smelter had a "modest profit"
 in tte first quarter of 1983. it had
 a large loss last year.
   "Foreign competition is bring
 more and more (copper) material
 into tte (IS. every year," Uad*
                     _      in tte coojrtry by tte
                 EPA, One of tte metals Involved
                 la arsenic  tasmiishly from tte
                   • PSAPCA has gtvaa tte smalt-
                 er until IttT to put toto affect a
                 salfur dkmde from its
                 Tte ***r***** says it
                 only about 45 penett
                 it would have to rebuild tte wteto
                 plant to do better. Meanwhile tte

                             •<> *iKlMP»
                             il* frMjU!
                             Fit !i \im\
                              if   Ml!
  - -PiH
  ir r ,8 if I
- a
** eo

PRO:   Many   Rustonites
     ite   smelter's    benefits

  HUSTON - "Baloney."
  This epitHet spoken politely but
firmly was Owea T. Gallagher's
considered opinion of tte Environ-
mental Protection Agency's wam»
inp this week about tte hazard*
of living ia the  shadow of the
Asarco smelter's smokestack.
  All  of  this half-mile-square
town of 600 residents lies within
the 1-mile radius of the smelter —
the area where the EPA said the
chances of contracting incurable
lung cancer are 33 percent higher
than elsewhere.
  Owen Gallagher scoffs at the
EPA's warnings and the call by
some  environmentalists for the
agency to tighten its restrictions
on cancer-causing arsenic smelter
emissions to levels that could
force the smelter to shot down.
  "They're going to kill tte goose
that  laid the golden egg," said
Gallagher, seated ia his neat brick
home  Just five blocks from tte
   fte smelter, tte  town and its
residents, he said, have enjoyed a
mutually comfortable relationship
for more than 90 yean.
  Gallagher well knows how tte
three  are intimately connected.
The lives of Gallagher, tte Asarco
 smelter and this town near Point
 Defiance Park are intricately in-
   Gallagher  was born here OB
 North Winnifred  Street,  four
 blocks from tte smelter gate.
 more  than 70  years ago.  He
 worked for Asarco  for 43 years.
 starting as a laborer ia tte copper
 smelter and retiring fir* yean
 ago as personnel manager.
   Gallagher is a legend ia town
 politics. He founded tte volunteer
 fire department. He served on tte
 Town Council for IS years. He was
 mayor for 20 years before step-
 ping down two years ago.
   During bis years'of'public ser-
 vice, said Gallagher. Asarco was
 good for Rustoo and its  people.
 The smelter provided as much as
 70 percent of the town's budget.
 furnished steam  to heat the Rus-
   n Elementary School and band-
  -mely paying jobs to support a
 number of its residents.
   Environmental restrictions that
 could threaten tte smelters very
 existence, said the former mayor.
 are "just a bunch of foolishness."
   Living by the smelter does pose
Owen Gallagher
  said, but tte benefits far outweigh
  Just recentiy, te said, after tte
smelter restarted its furnaces that

threat of a strife that didn't mate-
rialise, tte  area was Ut with a
sooty fallout. It landed on can in
Rastoa aad on boats at tte nearby
Tacoma Yacht Oub.
  "All yoWe got to do is go out
aad five your ear a quick wash,"
te said. "If yea leave it on. it
might eat into tte name"
•  But tte smelter hat to
about taking care of any i	
"The smelter has painted a let of
can over tte yean," te said.
  Tte payoff far tte
                      than in
               garbage service
  here is fret, he said. With tte ex-
  ceptioa of a single street, all of tte
  town's alleys and streets are
  paved without tte need for local
  residents to nay for them directly.
  Tte town employs a seven-mem-
  ber (two full-time aad five part-
  time) police fore*, a relatively
  large force for a town of Ruston's
  size, te said.
    More threatening than tte soot.
  tte EPA said, is tte 310 tons of
  airborne arsenic tte smelter em-
  its each year.
    Gallagher dismisses arsenic
    "When you're in a bakery, you
 • expect to get some flour on you."
 / he said.
    White tte smelter's chief;
  ic-containing byprc
                               are not nearly so benign, said tte
                                 Tte arsenic  emitted by the
                               smelter, tte EPA i
                                                                                        i •-»
                                                            es aa additional four cancer
                                                            deaths yearly ia tte Tacoma met-
                                                            ropolitan area.
                                                              If EPA Administrator WUttam
                                                            RackeJsteas adopts his proposed
                                                            arsenic limitation roles, those ar-
                                                            senic-related cancer death* in tte
                                                            Tacoma ana are expected to drop
                                                            to one.
                                                              But Racketaaaea, in tte first
                                                            test of bis new regime at tte em-
                                                            battled agency, tea asked those
                                                            touched by tte smelter's arsenic
                                                            emissions to  t*U him  if his  pro-
                                                            posed standards represent an ac-
                                                            ceptable risk level
                                                              A hearing is set for Aug. 30 la

                                                              If Gallagher aad otter Rastoa
                                                            town  officials are typical, ttea
                                                            many may speak oat against even
                                                            further  restrictions  that could
                                                            dose tte 87l> employee smelter
                                                            aad cat off UB aanaal f 33 million
                                                              Mary  Joyce and her husband
                                                            have raised their six children fig-
                                                            uratively in tte smelter's back-
                                                              Her home's  picture window
                                                            neatly frames tte smelter's 580-
                                                            foot tmoiestairk, a structure  Just
                                                            29 feet shorter than Seattle's
                                                            Space Needle.
                                                              Her home's elevated from yard
                                                            is landscaped with chunks of tte
                                                            black, obsidian-iike slag from tte
                                                             Joyce, a
                                                            said she knows of only one family
                                                            among Rattan's population that
                                                            has made any strong protest about

                                                             Those who are bothered by tte
                                                            SJBBttatti S ttjUeBsOOQeta 3ee4 SaUlta* Cl*
                                                            tter don't buy in Rastaa or they
                                                            move away.
                                                             "I think that if anyone felt that
                                                            strongly about it, they would
                                                            move. A person shouldn't have to
                                                            live IB a community if they're not
                                                            happy with if she said.
                                                             Rastoa Mayor Peter Brudevold
                                                            believes tte populace  here would
                                                            agree with him that tte smelter's

                                                            (Continued on next page)
  trioxide. bean an uncanny resem-
  blance to cake flour, its

              :   Many   Rustonites
cite   smelter's   benefits
 (Cantla from
 preceding pege)

 emotion past no major prob-
 "I think the greater majority
 would have to ape* with m* that
 then an no problems." h* said.
 Depoty Clerk Norm Doacette
 said she's unaware of any advent
 effects of tat smelter.
 "We have pretty lawns, and
 none of us have died from it (the
 emissions) yet that 1 know."
 "A lot of people blame the
 smelter for any problems  that
 they have." said Hasten Clerk-
 Treaswer Loretta Prettymaa.
 Not all the people  of Raton
 have the same high opinion of the
 smelter ipd its **niTTiimi
 Larry and Jean Wlngard stirred
 the displeason of some of the
 town hierarchy by filing  suit
 against the smelter for daman to
 their ear and their organic vegeta-
 ble garden.
 The coeni* lost the trial of their
 suit, bat they now have pledged to
 carry the fight against the smelter
 pollution onward.
 "fa long as there's a danger."
 she said, "we'll be then to fight
 Jean Wingard said many of
 those who welcome the smelter
 are unaware of the level or the
 dangers of the pollution. They
 have been blinded, she said, by the
 monetary rewards of working at
the smelter or by the services the
smelter's taxes boy.
 •They're getting paid down
then to live and work in it." she
said. "I'm  not getting paid to
breathe it"


                        Staff tuota by ««ucB LARSON
Healthful coexistence?

Seven-year-old Tonia Gibson is among dozens of schoot*
age children living in the path of emissions from the Asar-
co smelter who wiU be tested in a Tacoma-Pierce County
Health Department study during the next six weeks to
determine the levels of arsenic in their bodies and its
effects on their health.



                     .   Vashon  residents:   Fallout
                     "    'won't  let  us  enjoy  our  land'

common  people,  not rabbit-
rousen," said Michael Bradley, a
Vashoa Island constnctioo work-
er leading a groap threatening to
take Asarco lac to coon over itt
tOOC •""•fj*y«
  •Tm oot f or the km of job*,1'
Bradley was  careful to explain.
'Tm a constmctioo worker. I ap-
preciate industry and trades."
  But Bradley said he aad others
want the smelter to stop spewing
arsenic and other <**mfr«b>
  Bradley is chairman of a group
tentatively named Island  Rest*
dents Against Tone !
[RATE for short — that is prepar-
ing to battle on several fronts the
corporate bastion symbolised by
the smelter across  ra*n*m**».
meat Bay.
  The major concent of the groap
is the toxic arsenic aad cadiaittB*
deposited on the island, apparent-
ly from the smelter.
their life savings on a place and a
lorae are finding they caa't enjoy

of the Asarco plant." Bradley said.
  Many residents bought acreage
on rural  Vashoa Isiaad so they
could raise their own vegetables,
hogs and turkeys,  Bradley said.
And. he said, they purchased the
land long before  anyone knew
Asarco may be **•!""»'»'* for aa
 Michael Bradley

 island pollution problem.
   Bradley and other me
 the groap BOW dte a recent T	
          County Health Depart-
          IV B%f BlffWeMi' SlMtsMMi frthas)
  	which food (Bit soU oa
 Vashos •*"* Sfanrv *«*••<*• »»•• the
  '^^•^•^ ^^^ -^^^ g  ^^M^^W ^^M Vm^m

 and arsenic. The higheat level was
 found ID Tacoma's North End.
   VaahOB resideati also arc
 awaiting results of testa to
 mine the level of  arsenic «
 taiae of their children.
   Smelter Manager Larry

 were  harming  residents  of.
  ty Superior Court case ia which
  Rustoo residents Larry and Jean
  Wtagard failed to convince a jury
  that smelter •"niffi*"*- had poi-
  soned their garden,
    Tobia said the case had "several
  technical defects" in its i
    He m4 the Vashoa	
  be filed ia King County  instead.
  where be believes a jury may be
  gftj0gaxf synpitofo^
j   The attorney also noted that the
  Wiagards moved into  Rustoa.
  where they knew the smelter was
  already operating.
'. This (Vashoa) is a rural com-
  munity, not heavily populated.
  where a lot of people rely Heavily
 OB gardens for food." Tobia said.
   Tobia also said preliminary re-
 salts of a	
 property values OB the	
 pan of Vashoa may be adversely
 -*•	- by  the  smelter's  toxic
         real tttafe  agents  also
 have  said some  prospective
 boyen v/tll not look at property on
 the soBtbern part of the aUaad be-

 Tobtasaid.            ^..J...
              OB a aew Environ*
                                 "la all the yean
                               have taken soil
 al  that would order Asarco' to
            air-pollution  control
           TobiB said he is both
 	m— aad disturbed by the
  Tobta said he is happy the pub-
 lic will have  aa opportaaity to
         OB the proposal Bat he
                               leveb ia people. I            	
                               values  high tnough  to worry
contention there are  harmful
frttlth effects.'* he nH
  BIO ToMa. aa attorney living on
Vashoa. said the group mast de-
cide whether to file a class-action
suit or  individual  civil  suits
against the smelter.
  Because of the high smokestack
aad  prevailing  wind  directions.
Tobia explained.  "We  an  the
dumping ground for these pollu-
tants without any benefits (such as
jobs or Asarco tax payments)."
  The attorney said he is not dls-
couisged by a recent Pierce Conn*
 theRaston ana may
 toxic metals may esc-r-
 the stack and end up on V
  Ban  KJeia. aaother	,
 living on-Vashon who is active ia
 ELATE, said be thinks Asarco is
 simply "milking" the situation ia
 the Tacoma area as  moch as it
 caa while it prepares to shift its
      "    to other pans of  the

                                                               Kleia said the smetter has been
                                                             allowed to violate air pollution
                                                             regulations for years.
                                                               "Row many dates," he asked.
                                                             "can you go past go without stop-


frpHilf 8
•htm *i* —
 a a



                        Tacoma mayor
                        wants to keep
                        smelter open
 TACOMA (AP) - Tte
of Tacoma says te tavon
ing tte Asarco
open uutfl te u
                                        *^.^MM *—
                                        1000 tt
                        doot ttdnk it afaooid bt
                                on ABC* mttonafly
                          Satterlaad said flat

                        k^^ k^k^^ ^^^^^^^^ A^^^^_ *^
                        OH OMO LMUftU, OBBV V
                        whrtter tte HIM tiili illnnt pr»>
                        scot fo Tycoon jn 1*iniili to
                        Awco JMttil |U rnflHoB wertt
                        of^teodi ovar Us
                        vwtcrf to tnp put of
                        that Mcaiwteto tte «iri
                          Bat tte EPA luti pndkM tte
                        hoadifli act
                          Both AMTCO udEPA tew
                               standards ooold Com
                        tbepiant to shut down to comply.

       r r   ^ .. j  ,., "f-~f
       -TS." =••»=.: sV»«*
ifr ?i
in" 5
K- il
*** n
S "l!f illlp ilpl
                              . s

                    THC SEATTLE TIMES
                        19 Awg u
'3 should be dead, if
you listen to them...'
Longtime Asarco employees contend
health risks are exaggerated by EPA

HgK «• « dM pMH. I •• «tt
«M «tf tt» PMBk M« 1 »W «••
mm pfi i
to M 4HM ttMf » K. ft«
•MirMn}wan to I
                            IM a*
                            ri OK.
                Augug 19. 1983
Workers say
health risks

 You become immune  to arsenic
  To The Editor According to re*
cent headlines  in  the  Tacoma
News Tribune, I should have died
20 years ago. I  retired from the
Tacoma Smelter four yean ago,
after working there for 30 yean
The fint 20 yean I worked there,
I ate so much arsenic that when I
perspired  my  white  undershirt
would turn green from the arsenic
that came out of my body. No, the
aresenic did not till  me; and I
don't believe I will die from can*
cer. The human body builds up a
resistance to arsenic so that after
awhile you become immune to it
  The last 10 yean that I worked,
the smelter had cleaned up the air
so that I no longer  had  green
streaks  in  my  underwear.  The
main reason I retired early was
because of a regulation saying we
had to wear a respirator the whole
eight-hour shift
  You do-gooders don't  know
what you are talking about most
of the time. Sure, some people are
allergic to arsenic. The same  as
some people are allergic to their
wife or husband.  Heart disease
causes $1 percent of the U.S.
deaths. Cancer causes 21 percent
of the deaths in the U.S. Accidents
cans* 9  percent  of  the deaths.
Other causes account for the final
  So what part of  the 21 percent
cancer deaths is the Tacoma
Smelter responsible for?

           JOHN C. LARSEN,
             4S01 So. Warner

                     J**!** .af
                     «S-««fl= g-5 g
                    *S|f|3 lil


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                              Printed an Recycled Paper


                            LIST OF CONTENTS

                        ON RISK COMMUNICATION
      INTRODUCTION / WHY BOTHER?                               PAGE

      •     The Seven Cardinal Rules of Risk Communication. Vincent T.          1
            Covello and Frederick W. Allen. (U.S. EPA 1988).
      •     Risk Communication Problems and Tasks, adapted from "Risk          7
            Communication (A Review of the Literature)", a report prepared for
            the Environmental Protection Agency, August 1987, by Vincent T.
            Covello, Paul Slovic and Detlof Von WinterfeldL

      •     Some Jto's and Don'ts of Listening, from I Hear You, by Eastwood     9
            Atwater, from I Hear You. (Englewood & Clifts, New Jersey:
            Prentice-Hall, 1981), pp. 110-115.

      •     Improving Dialogue with Communities:   A Short Guide for           13
            Government Risk Communication. Caron Chess, Billie Jo Hance,
            and Peter Sandman (Trenton, N.J., Division of Science and
            Research, NJ. Department of Environmental Protection, 1987).

      •     Ten Ways to Lose Trust and Credibility, from "Improving Dialogue    45
            with Communities:  A Short Guide for Government Risk
            Communication," written by Caron Chess, Billie Jo Hance, and
            Peter Sandman (Trenton, NJ., Division of Science and Research,
            NJ. Dep-rtment of Environmental Protection, 1987).

      •     Letter, with attachment, from EPA Administrator Lee Thomas to       47
            U.S. Representative Henry Waxman. May 29. 1987.

      *     Differences Between Expert and Public Ratines of Environmental      55
            Problems. U.S. Environmental Protection Agency, Office of Policy,
            Planning, and Evaluation.

      •     The Lethal Legacy of Risk. New York Times                       59


      •     Preparing for the Interview, written by Paul Lapsley of the            61
            Environmental Protection Agency. A piece written for the Risk
            Communication Workshop.

      •     Excerpts from a Presentation by Tom Vacor on the Role of the         63
            Media in Risk Communication.  Excerpted from Risk
            Communication; Proceedings of the National Conference on Risk
            Communication. January 29-31, 1986. Edited by J. Clarence
            Davies, Vincent T. Covello, and Frederick W. Allen. (The
            Conservation Foundation, 1987).

      •     Do's and Don'ts for Spokespersons.  Reprinted in the Risk            67
            Communication Student Manual, edited by Erin Donovan, Vincent
            Covello and John Slavick (Chemical Manufacturers Association,
            Washington, D.C. 1989).

      •     What Do We Know About Making Risk Comparisons. An article      71
            by Emilie Roth, M. Granger Morgan, Baruch Fischoff, Lester Lave,
            and Ann Bostrom. Risk Analysis.  Vol 10, No. 3. 1990, pp 375-

      •     What Should We  Know About Making Risk Comparisons, an          85
            article by Paul Slovic, Nancy Kraus, and Vincent T. Covello. Risk
            Analysis. Vol 10, No. 3, 1990, pp 389-392.

      •     Explaining Environmental Risk:  Some Notes on Environmental        89
            Risk. Peter M. Sandman. TSCA Assistance Office,  Office of
            Toxics Substance, U.S. EPA, November 1986.

      •     Risk Communication Training Instrument, developed by Region IX     119
            - Typical Questions and Responses at a Public Meeting.

      *     Ten Reasons to Release-Information Early, from "Improving           141
            Dialogue with Communities:  A Short Guide for Government Risk
            Communication,"  written by Caron Chess, Billie Jo Hance, and
            Peter Sandman (Trenton, N J., Division of Science and Research,
            NJ.  Department of Environmental Protection,  1987).


      •     Focus Group Technique, by Decision Research Corporation.            143

      •     EPA Title III Focus Group Results, adapted from material prepared     145
            for the Environmental Protection Agency by Elaine Arkin and
            David McCailum.

      •     Focus Groups and Risk Communications:  The Science of Listening     153
            to Data. An article' written by William Desyousges and Kerry V.
            Smith.  Risk Analysis. Vol. 8, No. 4, 1988, pp. 479-484.

      •     Planning Dialogue With Communities: A Risk Communication        159
            Workbook.  Caron Chess, Billie Jo Hance, and Peter M. Sandman.
            Environmental Communications Research Program, Rutgers
            University, 1989.

      •     Evaluating Risk Communication Programs: A Catalogue of Quick      203
            and Easy Feedback Programs.  Mark Kline, Caron Chess, and Peter
            M. Sandman.  Environmental Communications Research Program.
            Rutgers University, 1989.                               *


          United States         Aonl
          Environmental Protection Agencv '988
          Washington DC 20460      QPA-S7-020
vvEPA   Seven Cardinal
          Rules of Risk

              I here are no easy
               prescriptions for
               successful risk
              I communication.
               However, those who
               have studied and
               participated in recent
               debates about risk
               generally agree on
seven cardinal rules. These rules
apply equally well to the public and
private sectors.
   Although many of the rules may
seem obvious, they  are continually
and consistently violated in practice.
Thus, a useful way to read these
rules is to focus on why they are
frequently not followed.
Accept and involve
the public as a legitimate

A basic tenet of risk communication
in a democracy is that people and
communities have a right to
participate in decisions that affect
their lives, their property, and the
things they value.
Guidelines:  Demonstrate your
respect for the public and underscore
the sincerity of your effort by
involving the community early,
before important decisions are made.
Involve au parties that have an
interest or a stake in the issue under
consideration. If you are a
government employee, remember
that you work for the public. If you  .
do not work for the government, the
public still holds you accountable.

Point to Consider
* The goal of risk communication  in
a democracy should be to produce an
informed public that is involved,
interested,  reasonable, thoughtful,
solution-oriented, and collaborative;
it should not be to diffuse public
concerns or replace action.
Plan carefully and
evaluate your efforts

Risk communication will be
successful only if carefully planned.
Guidelines: Begin with clear, explicit
risk communication objectives—such
as providing information to the
public, motivating individuals to act,
stimulating response to emergencies,
or contributing to the resolution of
conflict. Evaluate the information you
have about the risks and know its
strengths and weaknesses. Classify
and segment the various groups in
your audience. Aim your
communications  at specific subgroups
in your audience. Recruit
spokespeopie who are good at
presentation and interaction. Train
your staff—including technical
staff—in communication skills;
reward outstanding performance.
Whenever possible, pretest your
messages. Carefully evaluate your
efforts and leam  from your mistakes.

Points to Consider
• There is no such entity as "the
public"; instead,  there are many
publics, each with its own interests,
needs, concerns, priorities,
preferences, and organizations.
• Different risk communication
goals, audiences, and media require
different risk communication

Listen to the public's
specific concerns

if you do not listen to people, you
cannot expect them to listen to you.
Communication is a two-way activity.

Guidelines: Do not make
assumptions about what people
know,  think, or want done about
risks. Take the time to find out what
people are thinking: use techniques
such as interviews, focus groups, and
surveys. Let all parties that have an
interest or a stake in the issue be
heard.  Identify with your audience
and try to.put yourself in their place.
Recognize people's emotions. Let
people know that you understand
what they said, addressing their
concerns as well as yours. Recognize
the "hidden agendas," symbolic
meanings, and broader economic or
political considerations that often
underlie and complicate the task of
risk communication.

Point to Consider
• People in the community are often
more concerned about such issues as
trust, credibility, competence,
control, voluntkriness, fairness,
caring, and compassion than about
mortality statistics and the details of
quantitative risk assessment.
Be honest, frank,
and  open

In communicating risk information,
trust and credibility are your most
precious assets.

Guidelines: State your credentials;
but do not ask or expect to be trusted
by the public. If you do* not know an
answer or are uncertain, say so. Get
back to people with answers. Admit
mistakes. Disclose risk information as
soon as possible (emphasizing any
reservations about reliability). Do not
minimize or exaggerate the level of
risk. Speculate only with great
caution. If in doubt, lean toward
sharing more information, not
less—or people may think you are
hiding something. Discuss data
uncertainties, strengths and
weaknesses — including the ones
identified by other credible sources.
Identify wo'rst-case estimates as such.
and cite ranges of risk estimates
when appropriate.
Point  to Consider:
• Trust and credibility are difficult to
obtain. Once lost they are aimost
impossible to regain completely.
                                                        Coordinate and
                                                        collaborate with  other
                                                        credible sources

                                                        Allies can be effective in helping you
                                                        communicate risk information.
                                                        Guidelines: Take time  to coordinate
                                                        ail inter-organizational  and
                                                        intra-organizational communications.
                                                        Devote effort and resources to the
                                                        slow, hard work of building bridges
                                                        with other organizations. Use
                                                        credible and  authoritative

 intermediaries. Consult with others  •
 to determine who is best able to
 answer questions about risk. Try to
 issue communications jointly with
 other trustworthy sources (for
 example, credible university
 scientists, physicians, or trusted local
 Point to Consider
 • Few things make risk
 communication more difficult than
 conflicts or public disagreements with
 other credible sources.
Meet the needs of
the media

The media are a prime transmitter of
information on risks; they play a
critical role in setting agendas and in
determining outcomes.

Guidelines: Be open with and
accessible to reporters. Respect their
deadlines. Provide risk information
tailored to the needs of each type of
media (for example, graphics and
other visual aids for television).
Prepare in advance and provide
background material on complex risk
issues. Do not hesitate to follow up
on stories with praise or criticism, as
warranted. Try to establish long-term
relationships of trust with specific
editors and reporters.
Point to Consider
• The media are frequently more
interested in politics than in risk;
more interested in  simplicity than in
complexity; more interested in
danger than in safety.
Speak clearly and
with compassion

Technical language and jargon are
useful as professional shorthand. But
they are barriers to successful
communication with the public.
Guidelines: Use simple.
non-technical language. Be sensitive
to local  norms,  such as speech and
dress. Use vivid, concrete' images
that communicate on a personal,.
level. Use examples and anecdotes
that make technical risk data come
alive. Avoid distant, abstract,
unfeeling language about deaths,
injuries, and illnesses. Acknowledge
and respond (both in words and with
actions) to emotions that people
express—anxiety, fear,  anger,
outrage, helplessness. Acknowledge
and respond to the distinctions that
the public views as important in
evaluating risks, e.g., voluntariness.
controllability, familiarity, dread,
origin (natural or man-made),
benefits, fairness, and catastrophic
potential. Use risk comparisons to
help put risks in perspective; but
avoid comparisons that ignore
distinctions that people consider
important. Always try to include a
discussion of actions'that are under
way or can be taken. Tell people
what  you cannot do. Promise only
what  you can do, and be sure to do
what  you promise.
Points to Consider:
• Regardless of how well you
communicate risk information, some
people will not  be satisfied.
• Never let your efforts to inform
people about risks prevent you from
acknowledging—and saying—that

 any illness, injury, or death is a
 • If people are sufficiently motivated.
 they are quite capable of
 understanding complex risk
 information, even if they  may not
 agree with you.
77iis pamphlet was drafted by Vincent T.
Covetlo and Frederick W. Allen, ii'ith the
assistance and review ot numerous
colleagues in and out of government.
Covello is Director of the Center tor Risk
Communication at Columbia University
and is currently  President ot the Swiety
for Risk Analysis tSRA). The vines
expressed here do not necessarily
represent the vieii's ot Columbia
University or the SRA. Allen is Associate
Director of the Office of Policy Analysis
at the Environmental Protection Agency
(EPA). The EPA has published tins
pamphlet as a non-binding reference
document,  recognizing that the manner
in which the guidance should be applied
will necessarily vary from case to case.
Ttie authors invite uour comments.


 Risk Communication  Problems and Tasks

Risk communication problems arise from (1) message problems (e.g., limitations of scientific
risk assessments); (2) source problems (e.g_ limitations of risk communicators and risk
experts); (3) channel problems (e.g., limitations in the means or media by which scientific
information about health or environmental risks is transmitted); and (4) receiver problems
(e.g., characteristics of the intended recipients of the communication).

Message problems Include:

      a deficiencies in scientific understanding, data, models, and methods resulting in large
        uncertainties in risk
      a highly technical analyses that are often unintelligible to lay persons;

      O sheer amount of complexity of the analysis.

Source problems Include:

      a lack of trust and credibility;

      a disagreements among scientific experts;

      Q limited authority and resources for addressing risk problems;

      Q lack of data addressing the specific fears and concerns of individuals and

      Q failure to disclose limitations of risk assessments and resulting uncertainties;

      Q limited understanding of the interests, concerns, fears, values, priorities, and
        preferences of individual citizens and public groups;

      Q use of bureaucratic, legalistic, and technical language.
Adapted from Auk CamnuueiMiam -A Rtvit* of iltt Uttnuurt. i report prepared for die Eavaoainedul Protection Agency, August 1987. by
Vincent T. Covello. Paul Slovic lad Detlof Von WiourfeUL

Channel problems Include:
    '   Q selective and biased media reporting that emphasizes drama, wrongdoing,
          disagreements, and conflict;
       o premature disclosure of scientific information;
       o over implications; distortions, and inaccuracies in interpreting technical risk
Receiver problems Include:
       Q inaccurate perceptions of levels of risk;
       Q lack of interest in risk problems and technical complexities;
       Q overconfidence in one's ability to avoid harm;
       a strong beliefs and opinions that are resistant to change;
       Q exaggerated expectations about the  effectiveness of regulatory actions;
       a desire and demands for scientific certainty;
       Q a reluctance to make trade-offs between risks, costs, and benefits;
       O difficulties in understanding' probabilistic infoiiiuikMi related to unfamiliar
Adapted from Ac* CuHumuutmiat A Rfnifw of ato LUeramre, a report prepated for the Environmental Protection Agency. August I
Some  Dos  and  Don'ts  of Listening
by Eastwood Atwater
In a crisis situation, you wfll be laced with several different audiences requiring your
attention and ability to really "hear" what they are saying.
Here are some suggestions for improving your listening skills, but be reminded that mastery
of these skills requires repeated practice.
When listening, try to do the following:

1.   Become aware of your own listening habits.
     What are your strong points? What are your faults?  Do you judge people too quickJy?
     Do you interrupt too often? A better awareness of your listening habits is the first
     stage in changing them.
     Remember that it takes two to communicate— one to talk and one to listen — with each
     person alternating as the listener. Whenever you are unclear about what a speaker is
     saying, it is your responsibility to let the speaker know this, either by asking for
     clarification or actively reflecting what you heard and asking to be corrected.
     Be pfiysteofly attentive.
     Face the speaker.  Maintain appropriate eye contact. Make certain your posture and
     gestures show you are listening. Sit or stand at a distance which puts you and the
     speaker at ease. Remember that the one who is speaking wants an attentive, animated
     listener,  not a stone wall.

     Concentrate on what the speaker Is saying.
     Be alert for wandering thoughts.  Being physically and verbally responsive will
     probably help you concentrate on what the speaker is saying.
"Seme Dei «ad Doa'u of UiUDjng' from I Hear You, copyright 1986 by Eanwood Alwuer. Preauce H«ll. Englewood Cliffs. NJ I1'* I

5.    Listen for the total meaning, Including feelings as well as Information.
      Remember that people communicate their attitudes and feelings "coded" in socially
      acceptable ways.  Listen for the feelings as well as the content.

6.    Observe the speaker's non-verbal signals.
      Watch the speaker's facial expressions, and how much he or she gazes and makes eye
      contact with you. Listen to.the speaker's tone of voice and rate of speech.  Does the
      speaker's body language reinforce or contradict the spoken words?

7.    Adopt an accepting attitude toward the speaker.
      An accepting attitude on the listener's pan creates a favorable atmosphere for
      communication.  The more speakers feel accepted, the more they can let down their
      guard and express what they really want to say.  Any negative attitude on the listener's
      part tends to make & speaker feel defensive, insecure, and more guarded in

8.    Express empothetlc understanding.
      Use active, reflective listening skills to discover how other people feel, and what they
      are really trying to say in terms of their own frame of reference.
9.   listen to yourself.
     When you recognize die feelings stimulated in you by another's message, and can
     express those feelings, this clears the air and helps you to listen better.
10.  *Ctose th* loop" of listening by taking appropriate action.
     Remember that people often speak with the purpose of getting something tangible
     done—to obtain information, to change your opinion, to get you to do something. The
     acid test of listening is how well you respond to the speaker's message with an
     appropriate action. In listening, actions speak louder than words.
•Some Dot ud Don'u of Linening" from / Hear You. copyright 1986 by Euiwood Atwvn. Ptentice Hall. Englewood Cliffs. NJ.

While emphasis should be on positive suggestions.for improving listening habits, it is helpful
to keep in mind some of the pitfalls of listening.
Consequently, in listening, don't do the following:

1.    Don't mistake not talking for listening.
      People who remain silent aren't necessarily listening.  They may be preoccupied with
      their own thoughts. On the other hand, people can talk a lot and still process
      information and listen quite well.

2.    Don't fake listening.
      Whenever you try to fake listening, your disinterest or boredom inevitably shows up in
      your facial expressions or body language. More often than not, fake listening comes
      across as an insult  to the speaker.
                  i                             '                  •     .

3.    Don't Interrupt needlessly.
      People in positions of power tend to interrupt more often than those not in  power
      without realizing it If you must interrupt someone in a serious conversation, try to
      follow with a retrieval—helping the speaker to re-establish the  train of thought.
      Don't pass Judgment too quickly.
      Judgmental remarks invariably put others on the defensive, serving as barriers to
      effective communication.
      Don't moke arguing an 'ego-trip.'
      Even if you argue only "mentally" with what the speaker is saying, you tend to stop
      listening and look forward to your turn to talk.  When you begin to argue verbally. ><>u
      become so preoccupied with justifying your own views that you often fail to hear the
      other's viewpoint When you honestly disagree, you need to listen carefully in order M
      understand what you are disagreeing with.  Then state your point of view.
"Some Dot ud Don'u of Listening" from / Hear You. eopynghi 1986 by Eanwood Aiwicer. Prentice Hill. Eaglewood Cliffi M

6.    Don't ask too many questions.
      Closed questions that require a definite answer should be kept to a minimum.  Even
      open questions that encourage a speaker to elaborate on a point should be used with
      caution.  Too many questions have a way of shifting control of the conversation to the
      listener, putting the speaker one the defensive.

7.    Don't ever teff o speaker 1 know exactly how you feet/
      This remark  serves more to justify your own efforts than to convince someone you are
      really listening. In the first place, it is difficult to know just how another person feels.
      Then too, such a generalized remark is likely to distract the speaker from further efforts
      at self-expression, as well as  cast doubt on your own  credibility as a listener. It is
      usually more effective to demonstrate you have heard with a reflective, empathetic
      response such as "I sense that you are feeling disappointed," or "I get the impression
      you are angry about this."
8.    Don't overreact to emotional words.
      Be careful not to let yourself get so caught up in the speaker's outburst of feelings that
      you miss the content of his or her message.  Be alert for loaded words and expressions,
      but listen also for the message that comes with them.  Your own feelings can block
      your understanding of something you may really need  tojiear.
9.    Don't give advice unless It is requested.
      Even when someone asks your advice, it is better to use reflective listening skills to
      determine what that person wants to know.

10.   Don't use listening as a way of hiding yourself.
      People may use the appearance of listening as a way of avoiding emotional involvement
      and real communication.  The "listener" who uses silence as a personal retreat is
      inadvertently preventing effective communication, rather than furthering it
'Some Dos tad Don'ti of Listening- into / Hear You. copyright 1986 by Eucwood Alwater. Prenuce Hall. Eaflewood CUB*. NI.

                            Submitted to:

               New Jersey Department of Environmental Protecting
                    . Division of Science and Research
                           Contract #09444
                           December 14,1987
             (This report accompanies two related volumes: Improving
            Dialogue with Communities: A Risk Communication Manual for
           Government, and "Encouraging Effective Risk Communication In
              Government: Suggestions for Agency Management.'')
                           Carpn Chess
                          Associate Director
                          Billie To Hance
                         Research Associate
                         Peter M. Sandman
                 New Joser* A^iicultanl
                     Cook College, Rutgers University
                           122 Rydcrs Lane
                       New Brunswick, NJ 06903

                              TABLE OF CONTENTS
              How Communities See Risk
                    Factors in Community Outrage
                    Yes. But
        D.     Earning Trust and Credibility
                    Yes. But.
                    Ten Ways to Lose Trust and Credibility
                    Yes. But
                    Ten Reasons to Release Information Early
        IV.    Interacting with the Community
                    Ladder of Citizen Participation
                    Yes. But
        V.     Explaining Risk
                    Yes. But
        VI.    Ten Myths of Risk Communication
       Dulojne with Caauaaaiuet' wiittea by One Oiett. Billie Jo Haace. uu) Pcier Su4mu of the Eavaonineaul Commuaiciiion
HetotA Proinm tt Cook College. Rmgen Univenhy, 1987.


             Agency representatives who deal with environmental health issues often feel
       frustrated with communities that don't seem to listen and many times seem frightened
       of the "wrong" risks. In response, agency policy-makers and staff can choose to ignore
       communities (and in all likelihood face increased hostility).  Or they can choose to
       interact more effectively with the public.  This guide was written for those who under-
       stand that they must deal with communities but need some help in doing so.
       *     understand public perception and more easily anticipate community response to
             agency actions:
       *     Increase the effectiveness of risk management decisions by involving concerned
       •     improve dialogue and reduce unwarranted tension between communities and
       •     explain risks more effectively; and
       •     alert communities to risk in constructive ways.

             Communicating' about eiivtiuiiiueiitdl problems, however, cannot replace effec-
       tive risk management. This guide will not provide techniques to make environmental
       problems disappear. Although It might seem possible to sell "bad" policy with "good"
       communication, we doubt that communities will buy the result.

             Improving Dialogue with Communities" was made possible by a contract from
               on. of jj*><*"*'f «"^ Research (under tit* -^r^H Research Fund P" yi-»"'i) New-
       Jersey Department of Environmental Protection. Not only did DSR fund this project.
       but it also contributed substantive input and cooperated In setting up an advisory
       committee with staff of NJDEP and the New Jersey Department of Health.
             Because the research literature lags significantly behind the wisdom of many
       practitioners, who have been "experimenting" for years, the suggestions in this guide
       are based largely on interviews with more than SO academic experts, industry represen-
       tatives* <*<*<***> i^aH^r^ and agency «*gfl* throughout, thf country.  T^**** viffffv stions
       have undergone a review process involving both an advisory committee and those we
       interviewed.  The authors are grateful to all the people who agreed to be interviewed;
       they are listed in the longer version of this guide. Improving Dialogue with Communities:
       A Risk Communication Manual far Government

             Although based on extensive interviewing and a review of the research literature.
       this guide does not purport to be derived from quantitative analysis or entirely free of
       bias. We attempted to distill the wisdom. Judgments, values, and intuitions of those
       whom we interviewed in ways that would be helpful to practitioners.


             This guide, which to an abbreviated version of a longer manual, to useful to
_ those who wish a quick overview of how the public sees risk and how to Improve inter-
'Improving DUIofne with Ownmmhiw." wrinea by CVM Outs. Biilie Jo Hiace, and Peter Sudmu of the Eavaoameaul Commuajciuon
Re*e*rdi Progrsm n Cook College. Rotten Uaiverwy. 1987.

actions with the public. As such, this guide may help orient new staff or those unfa-
miliar with strategies for dealing with communities. It may also serve as a reference for
more seasoned practitioners,  *.    •

       Because most risk communication Issues are so Interrelated, we suggest you
read the entire guide first Pay particular attention to Chapter I. which lays the ground-
work for much of the guide. When you are dealing with a particular communication
problem, you may wish to consult the longer manual for more in-depth guidance.  If the
suggestion* here strike you a* a bit too "cut 1*™* dried." also consider consulting the
          ual fnrmnr» «tii»»iaittLiHni>  Although the guideyou are reading contains
nearly all the "guidelines" in the longer version and sections entitled "Yes, But..." to
deal with the most likely concerns, we have omitted a variety of features: (a) in-depth
explanations of the rationale for each suggestion; (b) extensive quotations from those we
Interviewed concerning the suggestions; and (c) anecdotes and examples that illustrate
the suggestions. (The complete manual is available from NJDEP's Division of Science
and Research. 401 East State-Street. CN 409. Trenton. 08625.)

       Finally, some of the suggestions may seem difficult to Implement without sup-
port from agency policy-makers.  This issue is discussed in a separate report. "Encour-
aging Rtsk Communication m Guv eminent: Suggestions for Agency Management." also
available from the Division of Science and Research.

       Many of the suggestions in this guide may seem common sense.  Unfortunately.
these common-sense guidelines are routinely violated in agency practice, leading to the
all-too-common battles between agencies and communities. We hope this guide will
t than the battles.
 "la^roviaf. Dialofoe wjth Commaajtiej.* wtitten by Ona Qnu. Billie Jo Huce. aad Peter Sindmiii of the Eaviromnenul Conunumca*
 RetMKfe Profnm it Cook College. Rmgen Univenity, 1987.
                                   '  16

                    I.  HOW COMMUNITIES SEE RISK
            Agency scientists and policy-makers are particularly confused and frustrated by
      public reactions to environmental risk.  Tempers flare at a public meeting concerning a
      risk that the agency estimates might cause considerably fewer than one-ln-a-million
      Increased cancer deaths. Yet people will smoke during the break and drive home
      without  seat belts— risks far greater than those discussed at the public meeting. When
      agency scientists point out this apparent contradiction (ignoring the fact that smoking
      and driving without a seat belt are risks that people choose, not an environmental risk
      that chooses them), people become even angrier. Conversely,  risks that the agency sees
      as serious—naturally occurring radon gas in homes, for example—can be met with
      relative indifference by the public.

            hi order to reduce the level of hostility between agencies .and the public, those
      who work within agencies need to understand better how communities perceive nsk.
      Agencies sometimes respond to unexpected community reactions by dismissing them as
      Irrational and concluding that the public is unable to understand the scientific aspects
      of risk. But when agencies make decisions that affect communities without involving
      th«M£ *»iirrtTTinr^»f«»^ they oftm *fa?** even, angrier rr?pr>p
variables that influence public perception— or worse, labeling them irrational and then
discounting them— is guaranteed to raise the level of hostility between community
members and agency representatives and will ultimately stand in the way of a success-
ful resolution of the problem.               .               '

       Merely hammering away at the scientific information will rarely help. Most
agency representatives can recall Instances when explaining the science made little
difference— or made people even angrier. While It may be tempting to conclude from
this that laypeople cannot understand risk assessment data, research In the field of risk
perception, backed by much anecdotal evidence, strongly suggests that other factors
are at work. Below are some of the key variables that underlie community perception of

a.     Voluntary risks are accepted mere readtty than those thai are. imposed.  When
people dont have choices, they became angry. Similarly, when communities feel co-
erced into accepting risks, they tend to feel furious about the coercion. As a result, they
focus on government's process and pay far less attention to substantive risk issues;
ultimately, they come to see the risk as more risky.

b.     Rtsks under individual control are accepted more readily than those under govern-
ment control  Most people feel safer with risks under their own control. For example.
most of us feel safer driving than riding as a passenger. Our feeling has nothing to do
wtth the data—our driving record versus the driving record of others. Similarly, people
tend to feel more comfortable with environmental risks they can do something about
themselves, rather than having to rely on government to protect them.

&     Risks that seem/air are more acceptable than those that seem unfair. A coerced
risk win always seem unfair. In addition, a community that feels stuck with the risk
and little of the benefit will find the risk unfair— and thus more serious. This factor
explains; m part, why communities that depend on a particular industry for jobs some-
times see pollution from that industry as t**» risky.
tL     lUsfcttt/UmuUua that ajiiMJjhpwtmaftoortfv SUM tM
than ttformattonjrom unfrustujorthu sources.  If a mechanic with whom you have quar-
relled in the past suggests he cant find a problem with a car that seems faulty to you.
you win respond quite differently than if a friend delivers the same news. You are more
apt to demand justification, rather than ask neutral questions, of the mechanic. Unfor-
tunately, on-going battles with communities erode trust and make the agency message
Jar less believable.                                                .
       While the above factors are those most frequently stumbled over by government
agencies, social scientists have identified additional variables that are also likely to be
relevant to agencies dealing with the public about environmental health issues:

e,     Rtsks that seem elhfcoOy objectionable urfQ seem more risky than those that don't
To many people, pollution Is morally wrong.  As former EPA Assistant Administrator
Milton RusseD put. It. speaking to some people about an acceptable level of pollution is
Uke talking about an acceptable number of child molesters.
         tfhhoffi Ptflil jsttan*c. •qyi-^a™*i-M<'*i*iB***1* conducted
 •la^nmof Dialogue with GMMMBSUCS,' wtmea by Carao Oca. BOlie Jo HMO, tad Pettr Sudmu of the EovinainaKti Communication
 JUteiKfe Propim at Cook Collefe, Rafot Uaivcniiy. 1987.

      /      Natural risks seem more acceptable than ortt/tool rtsfcs. Natural risks provide no
      focus for anger, a risk caused by God Is more acceptable than one caused by people.
      For example, consider the difference between the reactions to naturally occurring radon
      In homes and the reactions to high radon levels caused by uranium mine tailings or
      Industrial sources.

      g.      Exotic'risks seem more risky than familiar risks.  A cabinet full of household
      cleansers, for example, seems much less risky than a high-tech chemical facility that
      makes  the cleansers.

      h,      Risks that are associated with other, meinornlrfe events are considered, more
      risky. Risks that bring to mind Bhopal or Love Canal, for example, are more likely to be
      feared than those that lack such associations.

             The greater the number and seriousness qf these factors, the greater the likelihood
      of public concern about the risk,  regardless of the scientific data. As government  agen-
      cies have seen many times, the risks that elicit public concern may not be the same
      ones that scientists have Identified as most dangerous to health.  When officials dismiss
      the public's concern as misguided, moreover, the result is controversy, anger, distrust,
      and still greater concern. None of this is meant to suggest that people disregard scien-
      tific information and make decisions based only on the other variables—the outrage
      factors. It does suggest, however, that outrage also matters, and that by ignoring the
      outrage factors,  agencies skew the balance and cause people to become still more
      outraged. This is the logic that  leads to the guideline that follows.

      Pay as  much attention to outrage factor*, and to the community's concerns, as to
      scientific variables.  At the same time, don't underestimate the public's ability to
      understand the science.

            Agencies too often focus on the scientific data and ignore the outrage factors.
      They pay the price for doing so. Insistence on dealing with the "right" risks, the "right"
      way. may seem to many outside the agency as arrogant at best. If you fall to attend to
      the outrage  factors and people's concerns from the outset, you win often be forced to
      attend to them later, after you have angered the public— a far more difficult situation.

             For example, communities which were not consulted during the decision-making
      process more readily fight agency decisions. Similarly, agency representatives have
      sometimes been shouted down when trying to present data because communities have
      felt their concerns were not acknowledged, much less addressed.

             Nonetheless, there are examples of agency successes. The New York Department
      of Health asked office workers their concerns and gave them opportunities for input
      following a fire that contaminated their office building with dloadn. Trust was built in
      the process.  NJDEP listened to— and responded to—community concerns in Clinton
      where extremely high radon levels were found, leading to a community response to
      NJDEP that seemed far more positive than in many other instances.  In Virginia, a
      developer involved the community in the risk assessment process, building sufficient
      credibility that when the risk assessment showed negligible risks, the results were
      believed. In most of these instances of success, communities that were consulted about
      their ^OTi'T'M^ were also helped to understand, tlK BgtpnpBt y*H Umiir understanding
            f to increase.
"Improving Dialogue with ComiBuaitiej." written by Caroo Chess. Billie Jo Haaee. and Peter Sandman of the EovBOnmewal Communicau.
Research Program at Cook College. Ringers University, 1987.

       In short, response to risk is more complex than a linear response to "the facts."
This does not mean that people dont heed to know— or want to know— the facts. It
means rather that agencies heed to take Into account other factors as weU.
*      Our Job is to protect public health.  That means relying on data, not deal-
ing with outrage/actors.

       There are basically three responses to this point:

       First, if you merely run with scientific Information and ignore the outrage fac-
tors, you will outrage the public.  As a result, risks the agency deems minimal will
become battlegrounds. Agencies win have less time for serious dskm. In short, one way
or another agencies wffl haieta deal with these factors.

       Second, in a democracy controversial issues are not merely determined by those
with technical expertise. For example, the experts in the Pentagon have great technical
expertise m weaponry, but few people, regardless of their political beliefs, feel that
American defense policy should be determined solely by the Pentagon.

       Third, data are not always complete, and management options are rarely perfect.
The public's raising other concerns can lead to better technical solutions.

•      If It were not/or activist groups, there would be no outrage.

       As anyone who has tried to organize a community can attest. It is hard to create
outrage when none exists. Advocacy groups can focus or direct the community's anger.
but rarely create tt. In fact, most environmental activists count on government to create
the outrage. In many cases where environmental officials blame public-interest groups
for blocking solutions, the blame needs to be shared by the officials themselves, who
unwittingly goaded the outrage by neglecting from the outset to listen to community
concerns. Instead of blaming citizens for not understanding risk, in short, agencies
might spend more time trying to understand citizen concerns.
        Diatogue with Coaunwutiej,- written by Cvop Qiew. B3U« Jo Hwce. tad Peter Saadmu 

            Agencies achieve trust, to large part, by being consistently competent, caring.
     and honest. If you communicate with honesty and fairness, your audience will often
     respond in kind.  On the other hand, slick packaging with a veneer of honesty is easy to
     see through and more likely to undermine trust than to build It.  Jim Callaghan. who
     spent many years advising industry, as senior vice president, of the public relations firm
     of Hill and Knowlton. puts It this way:  The only way to achieve credibility is to "be

            Of course, acting trustworthy is no guarantee that people will ultimately trust
     you. But if you Call to "be credible," you will virtually guarantee community opposition.
     m the form of both disagreement with the science and resentment of the agency.

                   Bruce Bentley. citizen participation specialist at the New York State
            Department of Environmental Conservation, points out that a key to building
            trust can be involving people In decision-making. A controversy over what to do
            with PCBs In the Hudson River was fueled by the lack of trust resulting from the
            agency's failure to ask people about disposal of the PCBs. Bentley says. "We
            failed to Involve people In determining what the criteria for a site should be and
            then went ahead and selected the site.... By that time, people were not willing to
            buy into tha criteria ^TMJ certainly, therefore* not willing to buy in*" the* ait&*

                   Conversely, trust can be built by dealing with the public forthrlghUy.
            When a flre contaminated a Btnghamton ofllce building with dloxln. the New York
            State Department of Health decided to make all working sessions of the technical
            risk assessment committee open to the public and the media. The committee.
            which consisted of people from the city, union members, and technical people
            unailUlated with the health department struggled with  difficult questions openly.
            Although the meetings were not public Information meetings, there was time
            allotted for questions at the end of each session. As Faith Schottenfeld. commu-
            nity relations specialist at the department pointed out 'It was really helpful for
            people to «ee the kmd of Interchange that west on betana ttea* experts when It
                        I£ duDcutt ooctxtons*                               i
            The guidelines in this chapter provide a framework for the more specific recom-
     mendations in other chapters.

     1.     Be aware of the factors which Inspire trust. Trust in an agency depends, in
     large part, on whether the agency: (a) seems competent: (b) seems caring: (c) encourages
     meaningful public involvement: (d) seems honorable and honest; and (e) takes into
     account the "outrage factors* which influence perception of risk.  (See Chapter 1.) In •
     essence, instead of pushing the public to trust them, agencies should strive toward
     acting consistently trustworthy.

     2.     Pay attention to process.  In many cases citizen opposition focuses not only on
     agency action (or inaction), but also on the manner in which the agency proceeded
     toward that action. Try. whenever possible, to involve affected communities in agency

     3.     Explain agency procedures. Communities need to understand government's
     internal workings, and agencies TT^J to show that they Tp.*ratr tn v™* logical manner.
     Indicate how public input fits into the process.

"Imprawiai Dialogue with Conunuaitiei.* wrineo by Caroa Chen. Billie Jo Huce. ud Peter Sandman of (be Environment!] Conunuaicam.o
Reward) Program at Cook College, Rutgers University. 1987.

   "People read the agencies arid thetr actions more carefully than they read the details of
  the studies..., Thai's what we haue generalized skill at*  Baruch Fischhoff, leading
  researcher on risk perception, Carnegie-Mellon University. -.'    ;;  :;   .    ::
4.     Be forthcoming with Information and involve the public from the outset. If
you fail to disclose information or involve people early, the public is apt to mistrust the
agency. The agency will then be put on the defensive.  (See Chapter m.)
B.     Foena on building trust as weU as generating good scientific data. As
explained In Chapter I, people's risk |«H jtwrtfcf are •»Mnm based solely on Mfyt
      12.    Don't give mixed messages.  Risk issues are sufficiently confusing that any
     inconsistencies—or seeming inconsistencies—can make matters worse. For example, if
     you tell a community that risks are minimal and then take samples wearing protective
     gear, to reduce confusion, explain the seeming contradiction before you take the action.

      13.    Listen to what various group* are telling you. Try to foster mutual respect
     and consideration with all stakeholders in an issue. Avoid offending any group, includ-
     ing activists.  Agencies tend to overestimate the power of activist groups. These groups
     can't create outrage: they can only nurture existing outrage.

     14.    Enlist the help, of wfniinthmg that have credibility with communities.
     Groups that have local credibility (not merely organizations which agencies believe
     should have credibility) can be involved in helping explain risks. However, this ap-
     proach can't replace forthrightness or more extensive community involvement.

     15.    Avoid •doted" meeting!. While casual meetings— the routine turning of gov-
     ernment wheels—are rarely suspect, private meetings—those closed to the public- are
     more likely to cause distrust.  The meetings agencies feel they can't afford for the public
     to know about are the very ones the public will probably eventually hear about. You
     may avoid many problems by keeping meetings open.

     16.    It yon ire dealing with a situation hx which trust is low, consider taking the
     following steps:                                         ,

     a.     Review the outrage factors in Chapter I and the  guidelines in this chapter.
            Consider which ones may have been violated.

     b.     Acknowledge the lack of trust: "I know you may feel I cant be trusted because
            the person who handled this case before me delayed in giving you the informa-

     c.     Indicate what steps you plan to take to prevent the trust-eroding actions from
          .  happening again:  "In order to make sure you get information as quickly as
            possible,  I am going to send you bi-weekly updates about the status of the
            situation. These updates will include all new data."

     d.     Ask those who distrust you what they feel would make them more likely to trust
            you. To the extent possible, implement their suggestions.

     e.     Respond;  on a personal level, when appiupilate fsee Chapter IV}.

     f.      Try to reduce reasons for distrust by sharing information and involving the
            public in  developing solutions (see Chapter IV).

     g.     Be patient. Dont expect all the people to trust you all the time, even if you feel
           you are totally trustworthy.

            Because it may take a lot of effort to recoup trust, expect to go out of your way
     for people.  If you are the person who aroused the distrust, acknowledge your mistakes.
      "Because communities don't trust us they forget what. 13 logieaL The reason they don't
      trust us ts ttuxtiofdtdJfttnoGtue1 tterrr trrthfdectstL>ivi»m **i * "_* P*H»T^
      pation Specialist. New York Department of Environmental Conservation.
•Improving Dulogue with Communities.' written by Ctroa OWN. BilUe Jo Hwce. tad Peter Sudmu of the Environment*) Commuaicaiiop
      Pragma u Cook College. Riagen University. 1987.

YES, BUT....
•     It seems that no matter what we do, some people mill never trust us.

      True. However, the fact that you can't earn the trust of an the people all the
time does not imply that you should forgo the effort. Check to make sure that— despite
a baste commitment to trustworthiness—you have not violated some of the basic prin-
ciples in this guide.  The agency may also be confusing trust with agreement;  people
fsm trust each, other's integrity ayd y^H disagree on fundamental matters.
 •^ fW •• Take a good look at most risk communication "horror stories" and you'll
 probably find a major breakdown In trust between government representatives and
 the public they are supposed to serve. The next time someone comes to you with a
 sob story about communicating with the public, you might want to hand them this
 tongue-in-cheek list. Or better yet. hand it out before the damage is done.

 2, -,   Don't Involve people in decisions that directly affect their lives. Then
        act defensive when your policies are challenged.


Hold onto in/ormation until people are screaming for it. While they are
waiting, don't tell them when they will get it. Just say. These things take
time." or "It's going through quality assurance."             ,"; :

Jonore peoptes'/eelinos. Better yet. say they are irrelevant and irrational.
It helps to add that you cant understand why they are overreacting to such --
•a small ilsk, v:X •••:;•;•: .\:::";Vr/'::;       , •. •' '.' "'.": '•'• " '. ..•;"•'•••• ^.J'.^-il^r"

Don't follow up. Place returning phone calls from citizens at the bottom of
your to do* list. Delay sending out the information you promised people at
the public meeting.    .  •           ".••..=   ...

{f you make a mistake, deny it. Never admit you were wrong.

       don't know the answers, fake it Never say 1 don't know.'
Don? speak plain English. When explaining technical information, use
professional jargon. ; Or simplify so completely that you leave out important
information.  Better yet, throw up your hands and say, "You people could
not possibly understand this stuff." '•  ••^^•^.^^^^^^^::.^:;-^-^ •,' .
   -•- •  '  •-.,.    • ••••.:..'"•     -       '.  . *" -  ':•-•••,::• • "••-'• • •'••'<;•••: •••,•:,; •':;••"-. •'-':•.•• • . .:•:: ' •- ~
   .;'•:.•-. ••-•.: ..;..;-',;..., ^:,. -••"...•_.• ._. ;•-:.;....;• ,::•.•::••'•' ....   "- "" ' -\ ••'!....' '':'""••"!"::".*."?<:•;'.:-:•:• ••••/•-:,/,"; -;•- ,i' ' '•
Present yourself liPce a bureaucrat. Wears three-piece suit to a town
      g at the local grange, and sit up on stage with
        leagues who are dressed similarly.
          ^*              ,            »
                                                             of your col-
        Delay talkiny to other agencies involved— or other people invoh^d wlthm
        your agency— so the message the public gets can be as confusing as pos-
        sible. .-  .  ..-;.- ./>  .«•    •/•'           :-   .  •-  -'-^  •"-=.:... :  -   "
                                       tole retattttff- to ptmptfi Kates to do ft.
        and has begged not to, send him or her out anyway. It's good experience.
                        i.* written by Cmem C&esi. Bfllic Jo tfaoce. ind Pear Sindmin of the Eaviroamenul Camnwmuui
RetCMch Propun tt Cook Caitcfe. Ratfea Univentty. 1987.

             Perhaps no other aspect of agency communication of environmental risk is so
       closely related to the agency's credibility as Its decision about when to share informa-
       tion with the public.  Agencies fear that releasing information early may lead to undue
       alarm or lead to disclosure of incorrect or misinterpreted data. Agencies also hold onto
       information while developing risk management options rather than going to the public

             But what agencies vtew as responsible caution, communities axe apt to see as a
       'cover-up' or as bureaucratic intransigence.  When health risks are Involved, regardless
       of the level of risk, communities find it difficult to accept any Justification for withhold-
       ing Information. Therefore, community anger over agency process may block possibili-
       ties for constructive dialogue over the risk itself.  Moreover, waiting to release informa-
       tion until the agency has made its management choices reduces the chances for com-
       munity participation In the risk management process, and thus lessens the chances of
       a solution acceptable to the agency and the community.
                         aflB&Ie* Susan. Santos. formerly with the Suoexlund
             EPA Region 1 and currently manager of the Risk Assessment Croup at E.C.
             Jordan Company, was once In • position where the release of test results was
             delayed for three months while the agency analyzed an additional round of
             samples. Interpreted the data, and decided whether EPA or state government
             should take the lead. By the time the agency let the community know the level of
             contaminants in their wells, residents were so upset with the agency that com-
             munication was extremely difficult, if not Impossible.

                    On the other hand. Bruce Bentley. citizen participation specialist with
             the Mew York Dqpaitineiit of Environmental Cumei >»Uuu. tefls- ofm county
             health department going door-to-door sampling wells for TCE and explaining the
             potential risk as soon as there was any reason for suspicion of contamination of
             private wells. Results of the tests were sent by mall. Informing residents of times
             for 'availability sessions" with state and county representatives to answer ques-
             tions.  People wen alerted to each step of the process before It happened, and as
             a result discussion with the community centered on the risk itself, not oh the
             The following suggestions provide guidance about deciding when to communi-
      cate and steps to take if you decide to delay release.

      1.     If people are at risk, do not wait to eomnranicate— and to act on—risk In-
      formation.  If a hazard is putting people at immediate risk, the agency should follow its
      mandate to protect public health without hesitation.
      2.     If the agency. la. investigating a potential risk, that people Aren't aware ol.
      the agency staoald MrioaBrjr consider making know* wfastt itls doing and why .
      When an agency announces findings from an investigation people have not been aware
       Dialogue with Commianies,' wrinea by Caroa Ckesi. Billie Jo Haace. and Peter Sandman of tfae Environmental Communication
Re*eard> Program tt Cook College. Rutgers University. 1987.                           •     .

of. the agency is forced to defend tts delay ft announcing the investigation, and to
Justify the possibility that people were exposed to a risk longer than necessary. The
public. In its anger over not being told, is more likely to overestimate the risk and far
less likely to trust any recommendations that the agency makes concerning the risk

3.     If It teems likely that the media or someone else may release the Informa-
tion before yon are ready, release it yourself. When information is leaked, agencies
lose the ability to shape the issues and are Instead engaged in playing "catch up* at the
expense of their credibility (uut the accurate portrayal of information.

4.     If It Is likely that the media will *flH la* with Information concerning an
on-going story while they are waiting  for you to speak, speak first.  When you wait
to communicate about an Issue that is already news, the press will shape the issue
without you. You may spend more time defending your views or your credibility.
B.     If you really don't trust your data, talk to the public about your procedures
but don't release the data.  Obviously, hold onto data for which your preliminary
review shows serious quality control ormethodologtcal flaws. However, be up-front and
    «H»fy»«« what ft?5 happened and when they will be able to g*t ««*«» results.
6.     If the preliminary results do show a problem—and you are fairly confident
of the results—release them and explain the tentativeness of the data. If you are
fairly confident that the data show a problem, then holding onto data for any length of
time for any reason is likely to be considered unconscionable. You will leave the agency
vulnerable to charges of cover-up later on and risk creating a great deal of anger.

7.     Before deciding to wait to communicate—especially if the news is bad-
consider the effect on the credibility of the agency representative dealing with
the public.  Because credibility can be a scarce commodity, difficult to replace, you
might make it a major variable in your decision about timing the release of information.
In particular, take into account the effect of your decision on those staff who are dealing
with the community.
8.     Release information while the risk management options are tentative.
rather than waiting to develop solutions. If they are not consulted during the deci-
sion-making process, people are likely to resent decisions that affect their lives. Con-
sider, instead, giving people risk management options, not decisions, when you release
the dn*n. Then work with them to develop risk management decisions. (See Chapter IV.)
9.     If you fed the information win not make sense unless released with other
relevant Information  **"f you don't have all the informatioa yet—wait to release
  *When you're designing on tnuesttgatton or a regulatory strategy, the communication
                   •"******* PHP'^fi Painty (^tmmt**bmmr' rt^^.t^^m^^ Pap»^HftiBtw tf
  "Inprenat Dufafw wi* Ca
  Re*eucfc Ptoftm it Cook Coikfe, R»fcn Umvmity, 1987.
by Ctrce Cheu. Billie Jo Ifaace, *mi feur ^m^art rf dw Ewriraameaul ConiMiaican

        "We get a great deal of criticism because people don't know what we're doing...* There's
        always going to be delay; there's always gotng to be problems. But at least we can tell
        them what we're dotng."  Gary Sondermeyer. Acting Bureau Chief, Bureau of Solid
        Waste & Resource Recovery Planning. NJDEP.
      It all at once. But explain to the public why you are waiting, and get the Informa-
      tion as toon aa you can.  If piecemeal release of information would seriously disrupt
      the agency's program or the public's M"tterjetar"^tris. tb.*" cpn^t^er delay. But take a
      harrf Tb; gj whether ^gpTa-rratti^na reaDy need to watt or, iii fa^t. nagtf to be handled
      better. If you wait, be sure to be clear, about your reasons, and say when the informa-
      tion will be available.
      10.    If you wait until the data are quality-assured to release them, use the
      time—and the preliminary data—to develop management options and advise the
      community on interim actions. If necessary. While the agency may choose not to
      release data until it is fully confident. It can still use those preliminary results to guide
                 about the risk, nr"1 possible mitigation eflbr**
                                       unlcate data or information for some other
                                                                            Use this
11.    If you are waiting to eo
reason, don't say you are waiting for data to undergo quality assurance.
      rationale only when It is the real reason. Agencies lose credibility when they tell half-
      truths or remain silent and let others fill In the information gaps— often incorrectly. If
      you need to delay release of information, you will generally do better by being forthright
      and not using quality control as an excuse.
      13*    uywof^e^occraev trttf yov can i* cos
                                                   re* rfgtrt aw«y •boot the risk.
      talk to the public about the process you are going through to get the information.
      etc. Don't merely remain silent.  In the absence of information from the agency.
      people may fill in the blanks of missing information themselves, or they may become
      more fearful thinking that the truth is too awful to be told.
      YES, BUT.
      •      Releasing Information early, while data are still preliminary and we don't
      have a clear yame plant (eaves the agency vulnerable to criticism.

             This guide is not suggesting releasing information without forethought and
      planning.  We are suggesting that you consider releasing the data if you trust them, and
      if you have developed some management options or a process leading to development of
      options. Although the agency Is obviously vulnerable to criticism, you may be more
      vulnerable if you hold QTHO Information.  You will be t^^lnff a gamble with your credibil-
"Improving Dialogue with Communiuej," wrinea by Caron Chen. Billie Jo Hioee. and Peicr Sandman of the Environment*! Commuiu..«i
Research Program at Cook College, Rtngen Uoivenily. 1987.

*      By releasing Information early, toe man cause undue alarm.

       You may cause greater alarm, compounded by resentment and hostility, if you
hold onto information. When people are not given information, they may think that the
truth is too awful to be told, or they may consider the agency uncaring.  Instead, con-
sider releasing information in context and with caveats, if necessary.
       We run the risk qf legal liability if we release Information early.

      The number of cases in which liabmty is a primary concern-' rather than a
response from a lawyer than "We want to do this, so can you help us deal with any legal
        ?' If. in fact, there might be a liability problem, vulnerability to legal action
should be weighed against the ten reasons given below for considering early release of
        Deins au  wn  o r          m                            h

  situation. However, agencies should seriously examine the implications of holding
  onto tnfnrnnrtlnn •.•The not ttinr you contemplate whether to make Information •
  public, consider some of the reasons to release information early:
   1./-, People are entitled to information that affects their lives.

   2.:;vyy; Early release of mformation sets the pace for resolution of the problem: •/.;".
   3. ^ If you waitthestory insyteskanyway^ TO                           •
$ :;  ~   T011 can bettercOTtiol the accuracy of information if you are the first to

,:•:.-::.«  ^"f^fn & wan IQsety to be time for meaningful public mvoJvement in dedsion-
        maklng if the infonnation Is released rmDmptly.

       'Prompt release of infbrmation about one situation may-prevent stmflar situ-
        ations elsewhere. •^"'••^ •:• ':.:•< •-,•..: ;v. .-.
            work is required to release information early than to respond to Inquir-
        te*«ttaclB. etcv that im^ht result from delayed release.  -       ,.  -
                    apt' to earn public trust if you release information promptly.
                     .  '.'^r "v'...- : -..'^ '...-.           ••
     . ;;:v.v.3f you wait, people may feel angry and resentful about not T^^nrig of the m-
                       ': '•.:"--'-'1'--' '"                ~
        People are more likely to «yugf*ift
              Agency staff and members of the public are apt to feel equally frustrated by
       stormy interactions. Both get weary of arguments that revolve around "who said what
       to whom when," rather than issues that contribute substantlvely to solving environ*
       mental health problems.

              In response, some agency representatives feel that the best interaction with the
       public la no interaction. They fervently hope that risk communication techniques will
       make the public go away and leave the agency to make decisions in peace.  However.
       there is a strong consensus among experienced practitioners that the solution to the
       problems described above is more, rather than less Interaction,

              Two cases illustrate this point and contrast markedly with the battles that
       sometimes characterize agency Interactions with the public:

                     In Tacoma. Washington EPA was confronted with a difficult policy
              question: How should the agency regulate an arsenic-emitting smelter that
              yiuvtdeJ a substantial, ecuuuuUc base for the miimiimHy?  The problem Involved
              (as environmental health problems often do) Issues of equity, economics, and
              community values tn addition to technical concerns. EPA decided to open the
              process to the  public, enabling the community to grapple with some of the
              uncertainties and Judgment calls that often face agencies.  While making clear
              that the final decision rested with the agency. EPA demonstrated by word and by
              action genuine Interest In the community's concerns and values. For example.
              EPA staff who lived In the area by the smelter critiqued presentations so that the
              agency better addressed community needs. To demonstrate EPA's commitment
              to soliciting input, Informational presentations were followed by quesUon-and-
              answer sessions tn anodU giuups, facilitated by people from outside' the agency.
              Occause QIC smetfier*eiosecL a oeetsvoti ws^s1 nwcmqtflnso^ out'trie ejtperttnent
              m Tacoma Is an example of an agency respecting community values and attempt-
              Ing to Involve people outside the agency meaningfully in the decision-making

                     Lois Clbbs of the Citizen's Clearinghouse for Hazardous Wastes (and
              previously a key citizen leader at Love Canal) relates a story in which a private
              developer was confronted with high levels of arsenic in groundwater. In the
              interests of selling homes and avoiding litigation, he provided potential homeown-
              ers with fond* to hire «technical consultant agreeable to both sides. The
              consultant or the community members themselves were Involved In every step of
              the risk assessment process, including developing sampling plans and determin-
              ing the assumptions on which the assessment was based.  When the risk assess-
              ment showed negligible risk, people trusted the results sufficiently to purchase
              When interacting with the public, consider the following guidelines.

       i.     Recognize the importance of community input. Citizen involvement is
       important because: (a) People are entitled to make decisions about issues that directly
             Cliffy Itvex (b) Input from the community Tt help the agency make' better deci-
       sions; fc) Involvement fn the process leads to greater understanding' of— ami more
       appropriate reaction to— a particular risk: (d) Those who are affected by a problem bring

"Improving Dialogue with Communities." wnani by Caroo Chen. Bitlic Jo Haoce. tad Peter ^B'tofiB of the Environmental Communicant -0
      Ptogratn at Cook Collep. Rutgers University. 1987.

 '^•Ttie community is the expert about possible routes of exposure and what they are most
  concerned about.* Raymond Neutra, Chief, Epldemlologlcal Studies and Surveillance
 ^Section, CalJfbmla Department of Health Services. ^;f«-^ ;%:;-V;.."'- -;-\ .-; ••;:•• •";••
different variables to the problem-solving equation; and (e) Cooperation increases
credibility. Finally, without community Input, battles that erode public confidence and
agency resources are more likely.
       To t**f extent TfTTiitTTlfT. involve tlie community Itt
         Agencies typically spend considerable eflbrt developing a risk
strategy, announce^ to the community, and then defend the strategy against the
onslaught of opinion— often a reaction to the agency's failure to involve those affected.
Instead, particularly with issues which are apt to provoke contiuveisy. consider involv-
ing the public in risk management decisions. Some practitioners and academic experts
also suggest public involvement in the risk assessment process, as illustrated by the
story at the beginning of this chapter.

       As illustrated by the "Citizen Participation Ladder* on the following page, citizen
involvement takes a variety of forms from fairly minimal participation ("Government
Power! to ettttens taking the lead ("Citizen Power*). Consider placing agency interac-
tions wtth the coramuntty at« higher nag on the ladder. Propose a higher level of
involvement from the outset rather than being pushed by the community to the next
rung.  Increasing the level of public participation is particularly important when: (a)
controversy exists; (b) feelings run high; (c) the agency genuinely needs input; or (d)
citizens request It*

*      Involve the community at the earliest stage possible. Meaningful Input is
easier before agency staff feel committed to a course of action.  Communities are also
more likely to be responsive to aaenciyidetowiica they ate intoi»e
                          THE STATE UNIVERSITY OP NEW JERSEY
                      Environmental Communication Research Program
                      A program of the Agricultural Experiment Station
         Cook Colege » 122 Ryder* lane * New Brunswick * New Jersey 08903 • 201/932-4795
        Citizen Power
      Government Power
   Citizens act without
  communicating with
• volunteer fire department;
• citizen investigation;
• dtizen development and
 implementation of programs
Citizens and government
 solve problems together
• funding of citizen groups to
 hire technical consultants
 and/or implement projects;
• citizen oversight and
• meetings called jointly by
 government and citizen groups
                           Government asks citizens  • citizen advisory committees;
                           for meaningful input and  • informal meetings;
                                          •        •most public hearings;
                           Government asks citizens  • mo,! requests for responses to
                             for limited input and     formal proposals;
                           would prefer not to listen  • pn>forma meetings and
                                                   advisory committees
                              Government talks;
                                citizens listen
                      . • some public meetings;
                       • press releases and other
                        informational strategies:
                        newsletters/ brochures, etc
Government acts without
'Improving Dialogue with Communities." written by Ciroo Cheu, Billie Jo Hance, and Peter Sandman of the Environment*! Commuoicatibtt
Research Program at Cook College. Rutgen Uoivrany. 1987.
                                                  Risk Communication: Resources • 21

 'People have to identify with people as human beings.... Rapport ts the key.'  Vincent
 Covello, Director. Risk Assessment Program. National Science Foundation    •:.
•      Try to Identify the various interests in t situation at the beginning and
meet with them informally. Tills involves a networking process: (a) Make a list of the
aspects of the issue and types of organizations that might be interested: (b) Contact
groups with which you are familiar; and (c) Ask those groups for the names of others.
then contact the affected groups.  Keep working to expand the range of constituencies
to ensure that you have consulted those affected by the issue.

•      Recognize the strengths and weaknesses of citizen advisory groups. Define
the role of the group from the outset* Such groups work most effectively if they
represent the affected public and involve people in meaningful ways, rather than dis-
tance the agency from concerned citizens.  Before developing a citizen advisory group.
consult the full-length version of this manual (see Introduction).

*      Seal with everybody equally and  fairly. For example, don't give one group in-
formation that you refuse another. Be especially careful not to favor industry or local
government over environmental organizations.

4.     When appropriate, develop alternatives to public hearings. In particular.
hold smaller, more informal meeting!. Large public meetings often lead to posturing
on both sides rather than problem-solving or meaningful dialogue.  Instead of waiting
until a formal meeting is necessary, consider other options for exchanging information.
such as drop-in hours at the local library for questions, newsletters, telephone hot
lines, information booths, advisory committees, etc.  Most importantly, attempt  to hold
informal meetings with interested parties and maintain contact on a routine basis, the
more controversial the issue, the wiser it is to meet with the affected groups frequently.
separately, and informally.

•      If yon cannot avoid a large public meeting, the logistics should be devel-
oped so that both the agency and the community are treated fairly.  For example.
structure a meeting so that people do not feel upset by having to watt a long time to

*      Consider breaking larger groups into smaller ones. This approach can be
helpful for questlon-and-answer sessions or discussion groups.

•      Be clear about the goals for the meeting. If yon cannot adequately fulfill a
citizen request for a meeting, propose alternatives.  Prepare so that you can attain
the goals of the meeting and meet citizen concerns. If you do not know or cannot
address those concerns, meet informally to discuss community needs and to develop a
meaningful process to address those needs.

•      In certain situations one-to-one communication may be best. When sam-
pling, it is critical to prepare technicians to respond to people's questions, or provide
them with literature to hand out and a phone number for residents to call. Also, leave
time after meetings to respond to personal concerns.

 "Improving Dialogue with CommuniueJ." wnnea by Caroo Chen. Billie Jo Hues, aod Peter Sandman of (he Environmental Commuaieaiion
 Research Program at Cook College. Rutgera University. 1987.
 22 • Risk Communication: Resources

      5.     Recognise that people's value* and feelings are a legitimate aspect of envi-
      ronmental health issues, and that such concerns may convey valuable informa-
      tion. Peelings are not only an inevitable part of environmental health issues, they often
      contain valuable Information about: (a) what Is Important to people: (b) technical as-
      pects of the problem, such as the frequency and duration of an odor; -and (c) creative
      approaches to solving the problem.

      •      Provide a forum for people to air their feelings. People will become more
      frustrated when an agency attempts to squelch their saying how they feel. Provide
      mechanisms for expression of feeling, such as telephone hotlines, small meetings, and
      on ft* to* cm c
     »      Listen to people when they express their vataes and feelings. When people
     do not feel they are being heard, often they will express their concerns more loudly.

     •      Acknowledge people's feelings about an Issue. Try restating what people have
     said so that they know you have heard them: 1 can tell that you are angry about this
     proposal because.../

     •      When people are speaking emotionally, respond to their emotions. Do not
     merely follow with data. Do not use scientific data in an attempt to refute feelings or
     concerns, instead, acknowledge the feelings and respond to the concerns in addition to
     •      Show respect by developing a system to respond promptly to calls from
     community residents. Put calls from community residents toward the top of the
     priority list and develop mechanisms for your program to handle them efficiently.

     •      Recognise and be honest about the values incorporated in agency deci-
     sions. Communities sense when there is more going on than science.. and the agency
     loses credibility unless tt acknowledges those issues. .
     *      Be aware of yoor own tallies and feelings about an Issue and the? effect they
     have on you. Agency representatives also become invested in positions or feel strongly
     about issues. Recognize when your own feelings cause you to resist modifications of a
     project or to react strongly to a community group.
     6.   .  Prepare responses to personal questions about risk. Agencies develop poll:
     cles to protect public health generally, but individuals are usually most interested in
     how a risk or policy specifically affects them and their families. Anticipate and prepare
     honest responses to such Individual-level questions, including those asking you what
     you would do in a similar situation: "Would you drink the water?' Personal responses
     are particularly important when the situation is not clear-cut and people need some
     context for their own decisions.

     •      When yon speak at a public meeting, ten people who yon are, what your
     background is. and why yon are there.  Give people a sense of why you are qualified
     to discuss a topic and what you can and cant do for them.
       TTou realize that people need a forum to get those emotions and questions out and that
       If you can do that outside a large meeting which is impersonal ... tt con be much more
                 Susan 5fl***M. *^Ttftffftr, pf^if A«*»««m»Ttf f^^irj. ELC. Joriyi Company.
      fuiiiieily with h.t*A Region I Supcrfurtd program.
       Dialogue »iib Communities," wnoeo by Cvea Qius. Bilbe Jo Huce, ud Peter Sudmtn of the Environment*! Coaunuaication
Re**atcfa Program at Cook College. Rutgers University. 1987.

*      Let people tee yon are human. People win treat you as a person if you act like
one. If you act like a bureaucrat, you win be treated accordingly.       :

•      When speaking personally, put your views into the context of your own
values, and urge your audience to do the same. If you tell people how you might
handle a situation, put your response Into context (such as whether you smoke, exer-
cise, etc.) so they can do the same.
                                                               , do
the community.  Instead, try modifying the agency position or having the task reas-
signed. Or find a way of acknowledging the lack of consensus within the agency.  Mis-
representing the situation or dodging questions about your position will obviously
reduce your and the agency's credibility.

•      If speaking personally makes you uncomfortable, work on it until It gets
easier. If you just dont think it's appropriate, dont do it.
7.     UsecomanmttyRlatiomr staff to ainpltfy-coimirontty1 concerns wtthin: the
agency.  Instead of acting as buffers between the public and agency technical staff.
community relations people should make community concerns heard before the public
feels a need to shout.
8.     Choose carefully those who represent the agency and provide appropriate
support. Because agency representatives can give an impression of the entire agency,
they should be carefully chosen and given the time and training to do the job
adequately. PfOplff ^*>O ^| ^n*lr « TtimiM **"*• bg T»*pt
       YES, BUT-..
       »      As on agency, toe are supposed to protect health— not deal with feelings.

             As explained in Chapter I. protecting health will be quite difficult If you do not
       take into account community concerns.  Ignoring such concerns will not only lead to
       stress on  the part of the community, but ultimately will also undermine the agency's
       ability to implement risk management decisions.
      •      Communities worry about the •wrong'* risks. Involving them in decision-
      making will lead to poor policy.

             Public response to risk is not merely a function of the numbers but also involves
      other considerations, explained in Chapter I. such as equity. In many cases agency risk
      management decisions are also based on values, not merely technical factors. Agencies'
      itiihi«B> are no TTIOTT Ug<««rp^t«» iti^p e*fnnmm»\i*f _  Furthermore, in many cases if you do
      not involve the public, the subsequent outrage may lead to even less logical policy
      decisions. Just as important, communities often provide, valuable insight Into problems
      and creative approaches to solutions.
      •      We don't hove the time or resources to do the type of outreach recom-
      mended in this guide.

             Some changes suggested In this guide do not take more time and money—
      feelings than to argue with them. Although involving the public In decision-making can
      be labor-intenstve. to some eases it is far more efficient than the alternative. Finally.
      the quality of projects can increase as a result of a diversity of input, thus reducing the
      likelihood of having to back up and rectify oversights.
"Improving Dialogue with Comnuaitiei.* written by Ciroo Qieu. Bilbe Jo Htnce. tad Peter Sandmu of (he Eavaonmeau! Commuiuciii.-n
Reieircfa Prognm *i Cook Cdtege. Rtncers Uttiveniiy. 1987.

                              V.  EXPLAINING RISK

             Agency representatives sometimes believe that if they could only find a way to
      explain the data more clearly, communities would accept the risks scientists define as
      minimal and take seriously the risks scientists see as serious.  However, simply finding
      ways to explain the numbers more clearly is not the panacea practitioners might hope
      for.. While searching for the magic formula that will help people calm down about the
      small risks and wake up about the big ones, agencies may overlook key variables that
      influence public perception of risk.  (See Chapter I.)
                    Ftor example. tUDCPAasl
          Donald Deiesotdla the
             •toy of attempting to explain the additional risk of* resource recovery facility to
             • community that had little chance for input before the permit was granted.
             Instead of responding to Information about the minimal risk posed by the facility,
             the member* of the audience Jeered. Although scientists felt the increased risk
             was negligible, the agency's process spoke louder than the risk numbers. It1
             unlikely that any magic combination of words explaining the risk would have
             reduced the hostility caused, in part by the community* lack of power.
                    On the other hand. Sit
of the E.C. Jordan Company, who
             fenneriy worked for EPA Region I, spent considerable effort dealing with commu-
             nity concerns when she served a* EPArepresentauveoik aSuperfund atte with a
             history of unsatisfactory interaction between the community and the agency.
             During her first meeting to update community residents, they essentially shouted
             her down, accusing her of being another EPA employee who would not listen to
             them. They suggested that before she spoke with authority she go through their
             flies of Information, which she dtd. Santos 'got very Involved In finding out what
             their concerns and fears were- whether they were real or not— and Initially not
             worrying about whether to confirm or sway (heir fear*, but Just letting them
             know that someone was out there to listen to what their concerns were....*
             Santos' obvious Interest in community concerns helped to turn the situation
             to take the time at the outset can cost the agency more time in the long run.

             Although "explaining* skills are also relevant, the moral of these stones is that
      the agency's attitude toward and interaction with the public are key variables in ex-
      plaining risk.
      1.     Consider the ontzmge factors when explaining risk. In order to avoid upset-
      ting people you must first understand what upsets them.  (See Chapter I.) Although
      some of the factors that contribute to community anger are not susceptible to agency
      control, the agency can Influence others, such as how fair a risk Is or the extent to
      which citizens can exert control over the risk.  If the agency is forthright in its commu-
      nications and involves the public, public perception of the risk is more likely to be on

      •      Be prepared to give people's concerns as much emphasis as the numbers.
      Give as much consideration as possible to community concerns and feelings.  Many
      people make their decisions based on their feelings, their perception of the agency, their
      sense of Justice, etc. Numbers alone will rarely sway them.
      (See diautei m.)
                                                      tfe* situation
•tapravtai DulofM wi* Commoaiue*/ *rioea by CJTQB Chen, Biltic Jo Hwtce, utd Peter Sudmu at the Eavwooncattl Co
RHcaidi Proffim at Cook Collefe, Rmgcn Uaivcntty. 1987.

 •      Be sensitive to related Issues thst may be more Important to many people
 than the risk itself. Expect different people to see the risk differently. Sometimes the
 risk that practitioners are trying to explain is secondary to people's other concerns.
 such as property values.  Regardless of whether the agency sees these concerns as
 Important or within the scope of the agency's authority, they can critically influence a
 community's views. Try to Identify and address these concerns. If you cannot address
 them, at least consider acknowledging them and explaining why your agency cannot
 deal with them.
2.     Find out what risk information people want and In what form. There may
be differences between the risk infdnnatton scientists and regulators tfamk communities
should have and the information communities actually want Before presenting risk
information, understand community concerns by meeting with the community or
developing a checklist of likely concerns based on agency experience with similar situ-
3.     Anticipate and respond to people's concerns about their personal risk.
Consider responding personally. Although agencies are concerned largely with risks to
populations, people are most concerned about their own risk and that of their families.
Prepare to respond to personal concerns ("Can I drink the water?") and incorporate
answers in presentations a**^ \nfrfrrnat1nrt9l materials. Some practitioners suggest "
speaking personally and gtvtng an individual perspective on the risk, while making clear
the distinctions between agency policy and your personal opinions: "The levels of con-
tamination in your water are low enough that the agency feels you can continue to
drink it without worry. Personally. I would drink the water. My sister, however, tries to
eat mainly natural foods and I suspect she would be concerned enough to consider
drinking bottled water- despite the fact that bottled water is not regulated."
Most people do not have the same frames of reference as scientists and need some   ,
background to put the risk in perspective.

•      If you are explaining numbers derived front a risk assessment, explain the
risk assessment process be/ore you present the numbers.  Some practitioners have
held risk assessment workshops to explain the process even before the risk assessment
was completed.

•      Explain and. If possible, show In clear and simple graphics the routes of ex-
posure.  Frequently, the issue is not whether a dangerous substance exists in relatively
high quantities but whether the routes of exposure put people at risk.

•      Put data la perspective. Avoid dichotomising risk. Agencies should avoid
fueling communities' tendency to see risks as "safe" or "dangerous."  Instead of present-
ing standards as a cut-off figure, attempt to explain risk numbers in ranges: 1-10 ppb
as "low risk." for example.  Also show how data relate to similar data. To provide con-
  'Health matters raise very strong fears, concerns, and emotions among people. To
  treat it as a technical analysis and not to recognize the extent to which people feel
  strongly, not to acknowledge their concerns and/ears and attempt to* deal with them
  teajataf ntistafceu." Vincent CaveOa. Director of Risk Assessment. National Science
                  '                                          '
 •Improving Dialogue with Co
 Reteardi Program it Cook College, Rotten Univenity, 1987.
ariicx." written by Cvoa Chess. Billie Jo H«nce, and Peter Snidrrun of die Environment*] Common.-.*;

  TA slide comparing cancer risk from industrial emissions with the risk from diet soft.
  drinks] provoked.a lot of negative reaction,. People said  7 con choose to drtnfc or not to
  drink diet coke, but J can't choose riot to breathe.' Nobody Is going to make a decision on
  asmelter based on how the risk stacks up against the trtgesttonrtskjrom saccharin in diet
  coke.' Randall Smith. Chief. Hazardous Waste Policy Branch. USEPAKcglonX.
 text for one community's data, for example, you might compare it to the regulatory
 action level and to the levels found in other communities in the state.

 •      Express risks in several different ways, making sore not to evade the risk
 question.  People whose ™<"rf« arc not already **""** up art very tnfl'jfTKT^ by how
data are pr
                   Because no presentation of risk is entirely objective, ft may help to
 present risk in a variety of ways, expressing it both in terms that might make the risk
 seem larger and in ether terms that might make the risk seem smaller. This approach
 also reduces the tendency of agencies to minimize thg risk, which is likely to be viewed
 wtth skepticism by those outside the agency.

 •      Explain the agency's protective approach to risk assessment and standard-
 setting. People are often not aware of the extent to which buffers are built into risk
 assessments to ensure that they err on the side of caution. Because the word 'conser-
 vative*  has other connotations which may be misleading, substitute the word "protec-
 tlne* or 'cautious**
 B.     Take care when comparing environmental risks to other risks:

 •      Avoid comparisons that Ignore the "outrage factors.* The least useful and
 most inflammatory comparisons agencies can use are those that ignore the variables
 discussed in Chapter L  hi particular, beware of comparisons of .everyday activities
 people do of their own accord- such as smoking- to imposed risks. These compari-
 sons backfire most often when used to reassure people; they can be used a bit more
 freely when trying, to alert people to. risk.

 *      Avoid comparisons that seem to minimize or trivialize the risk. For ex-
 ample, it's generally not useful to compare parts per billion to sheets of toilet rolls
 spanning continents or drops in swimming pools.  Also, these comparisons assume
 (inaccurately) that low concentration necessarily means low risk.

 •      Develop comparisons of similar situations or substances.
             Use comparisons of the same risk at two different tones: In 1979 before
             regulation versus this year after regulation.'
             Compare with a standard: This level Is 25% below the federal standard
             and somewhat below the state guideline." (Use this comparison carefully
             if the standard la controversial.)
             Compare with different estimates of the same risk: your estimate of the
             risk aide-by-side with the industry assessment and the environmental-
             ists*. Then explain the diffe
             As stated previously, explain how the data relate to other data: the levels
             In one community compared to national averages, to other levels In the
             state, etc.

                                                            »you extremely vul-
                                          IBI utT at worst. Yea are better off
leading with an explanation of the uncertainty than watting to be confronted with it.
  Dialogue with Commoniuet.' wrinea by CJTOO Quest, Bfllie Jo Hwee. *od Pats
  Qfiam tt Cook Cdlege. Rut|en Univmny. 1987.
                                                        <3t the Emrounesttl CommuaicuioB

 *     Give people background on tbe inevitable uncertainty of science. Help
 people understand uncertainty so that they do not assume something is amiss if the
 agency says it doesn't know.

 •     Be specific about what you are doing to find answers. In order to avoid
 people thinking that you are hiding something or acting incompetently, explain the
 process you are using to find the information. Or explain why it is not possible to find.

 •     Consider involving the public in resolving tbe uncertainty. It is easier for
 people to accept uncertainty if they can play a role in Its resolution. This approach not
 only is likely to be perceived, as c**r*f bul may a1grt ^nd to fr**t** ««int
       •Value Judgments are part of the risk assessment process, but if you are part of defining
       those Judgments and those decisions then the outcome p/tt ts something you can trust *
       Lois Glbbs. Executive Director. Citizens Clearinghouse for Hazardous Wastes
      consider giving people more  control. Community monitoring, oversight, and on-going
      feedback can be measures that help people exert some control over risks and thus feel
      more comfortable with them.

      •     Acknowledge that there are other aspects of decision-making besides risk.
      and be prepared to listen and address people's concerns. People will often argue
      about risk when they're as omcemeJ about issues such as property values, because
      risk is considered a more legitimate issue by agencies. As said previously, it is usually
      helpful to recognize, acknowledge, and address these other era
      •     Belp people to help their neighbors decide what Is acceptable to them.
      Sometimes people can better accept problems when they can talk them over with
      others. Encourage rather than discourage dialogue.

      6.    Take even greater care presenting technical Information than presenting
      other information. Many of the keys for presenting technical information are the same
      as those for presenting ****** TmatlTm but are often- overlooked.
      •     Know your audience aad gear your presentation to its level Think through:
      (a) what the audience already knows; (b) what the audience wants to know; and (c) what
      you want the audience to know. When explaining technical information, it can help to
      imagine that you are talking to an intelligent but uninformed friend and speak at that
      can also help.
      •     Consider which information is most important to convey. This often in-
      cludes: (a) the facts your agency wants people to know about a situation; (b) the back-
      ground Information they need in order to understand the facts: and (c) the additional
      facts they need to know so they won't get misimpressions. Identify three or four main
      ideas you want to convey and make sure the details support those points, rather than
      obscuring them by sheer volume. Finally, make sure to address people's concerns
      rather than:just gtvtng tht fn***T

      •     Be sore to give people sufficient background. Dont assume that condensing
      Information is the same as making it clearer.

      •     Use as down>to*«arth language as possible. Watch jargon and acronyms.

      •     Beware of the tendency to oversimplify and give only data that support
      your point. People know when you are using ammunition for your argument as op-
      posed to presenting information.

      •     Choose supporting graphics that Illustrate your message clearly and simply.
      Be cautious about using, the same grapmca used for technical audiences.  Hastily: or ill-
      JMMM^^^^Mft MVMMtoly^' 4^M«» 1*^ ^^M^^ *!MM» ^^M»a  B^^Mk • •*!! 1.1 !••!*••> ^^_^WA^^	|fj ^.t* ^-»
      corggr^Bo. gnigtmpj fcai* oe? worseuminuue.  ii.uen weu-eapeoiretr giapmcs wm not go
      over well if they do not deal with people's concerns.
       Dialogo* with *>mii--i*iTf " written by Owe den. Bfllie Jo Haaee. «d Peter
Re*ufd> Propun at Cook CoJkge, Riacen Uonermy. 1987.
of the Environmanal Gmniiaicaiioo

 *     Be aware of body language and other signals your audience gives you that
 they're lost. Slow down, back up, or ask questions.

 •     Have background material available at meetings.

 •     Always have questlon-and-answer periods after presentations.

 •     Critique your presentation afterward, so yon ess learn from the things you
 did dghl as well aa.ibasft you did wrong.
•      We still don't have a clear ways to explain very complex Information.  If
we did, it'J likely the public would understand better.

       It is true that further research is needed about how to explain environmental
health risks.  EPA and DEP's Division of Science and Research are both funding proj-
ects in this area. However, regardless of our sophistication In explaining risk, people's
perception of the risk will be influenced by far more than scientific data. If you con-
tinue to stress explaining data and fall to attend to these other variables, you will
probably create problems.

      It Is extremely difficult to help people put entrtronmentaTneafth risfcs fn
               e* ctnt*t cotitpemf tftesvrtffcs* to u filer risfcs in people's lives.
       Comparisons can be used, but those employed by agencies are frequently not
helpful. Comparing voluntary to Involuntary risks and other comparisons that ignore
the outrage factors are apt to make people angry. Hie section on comparing risks in
this chapter gives examples of some useful comparisons. Further research is being
done to develop and test others.

•      lit if difficult to see why on agency should admit uncertainty when people
will use such admissions ayalnst us.

       This chapter suggests that people are already alert to uncertainty. Falling to
disclose uncertainty is likely to undermine trust in the agency. As suggested, agency
representatives should not merely admit uncertainty and then drop the subject. The
uncertainty should be put in context in several ways, as suggested in this chapter.
 'Improving Dialogue wjdt Commmutiej." written by Caron Qieu, Billie Jo Hince. ud Peter Saadnua of the Environment*! Commuwe*i.,,n
 Research Program at Cook College, Rutgers University. 1987.


            As with most myths, myths concerning risk communication have an element of
     truth.  But they should not be swallowed whole. The following beliefs often interfere
     with effective risk communication and deserve closer scrutiny.
      J.     We don't hove enough time and resources to do risk communication.  Risk
      communication, does take time and staff. But If yon dont devote efforts to interacting
      wtth the public, you may be forced to mop up-communications disasters- which typl-
      QBuQT tDBJG69' Q1OW IC9OQICC9*

      Suggestion; Tram the staff you have, including clerical staff who answer the tele-
      phone, to communicate more effectively.  Plan projects to include time to involve the
     2.     Communicating with the public about a risk is more likely to unduly
     alarm people than keeping quiet. Risk communication can be risky. But not giving
     p**1!1^ ^ «»ham*» to express their concerns is likely to increase rather than decrease

     Suggestion; Consider releasing Information earlier rather than later.
     3.     If we could only explain risks clearly enough, people would accept them.
     True, explaining risk is important. But data are not the only factors which influence
     people's perception of risk.

     Sugyestfuii. Pay as much attention to your process for dealing with people as you do
     to explaining the data.
     4.     We shouldn't go to the public until we hone solutions to environmental
     health problems. Problems can seem easier to deal wtth when coupled with solutions.
     But falling to Involve people in decisions that affect their lives may result In. tremendous
     Suggestion.* Release risk management options, not decisions, and involve communities
     in discussions of risk management strategies In which they have a stake.

     5.     These Issue* ore too tough for the public to understand. Environmental
     health issues can be complex. But as demonstrated by citizen groups throughout the
     country, laypeople can grasp a great deal of the substance.

     Suggestion; Do not assume that the public's disagreement with your policies indicates
     a misunderstanding of the science.
•Improving Dialogue with Commmitie*." wram by Oreo Chen. BiJlie Jo Hanee. ud Peur Saadmu of the Eavsoameaul Communication
Research Program at Cook College, ftmgen University, 1987.

 6.    Technical decisions should be lejt in (he hands of technical people.  Tech-
 nical staff generally are better versed in the scientific aspects of environmental health.
 But many of the problems government deals with raise policy and values issues that go
 beyond the technical realm.

 Suggestion.* Develop mechanisms to listen to communities' concerns about policy and
 values Issues. Inside the agency, Involve staff* with diverse backgrounds in developing  •

 7.    Risk communication is not my Job. True, you were probably hired because of
 other credentials.  But as public servants, agency staff have a responsibility to deal with

 Suggestion; Learn to integrate communication into your Job and help others to do the
 8.     \fwt give the public on inch* they'll take a mile. IT the interaction with the
 community more closely approximates a battleground than a discussion, this may be
 true. But if you listen to people when they are asking for inches, they are less likely to
 demand miles.

 Suggestion: Avoid the battleground.  Involve people early and often.

 9.     ffwe listen to the public, ive mill devote scarce resources to issues that
 are not a great threat to public health. In any public policy arena we can find such
 inconsistencies. But dosing out the public is likely to cause dlstrost and farther skew
 the policy debate.

 Suggestion; Be sensitive to public concerns. Otherwise you will unwittingly create
 controversy and contribute to raising the profile of issues of lesser significance.
10.    Activist groups ore responsible/or stirring up unwarranted concerns.
True, activists help to focus people's anger.  But activists do not create the concerns:
they merely arouse and channel those that already exist.

Suggestion;  Deal with the groups and their concerns rather than merely fighting
 •Improving Dialogue with Coaumiaittes." written by Caroa Own. Billic Jo Hiwe. ud Peter Sandman of the Environmental CooununicattoB
 Research Program at Cook College, Rutgers University. 1987.


                         1HE STA1E UNIVERSITY OF NEW JERSEY:
                    Environmental Communication Research-Program
                     A program of the Agricultural Experiment-Station
       Cook College • 122Ryders Lane • New Brunswick:•^ew. Jersey03903 •201/932-3795:::::
                                                                and you'll prbba-
      Take a good look atmostrtsk communica
    bly find.a major breakdown in trust between,government representatives and the public
                                    time someone comes to you with a sob story
they are supposed to serve.  The
    about communicating with the public;you might want to hand them this tongue-tor
  :? cheek,list.::::,Or:better.yet; hand.ltoutbef^

    1.   Don't involve people in decisions that directly ajfect their lives. Then act de-
  ;...^;...: fensive when yourpolicies.are.challenged.::':r.:':.^£^^^^j^^-^j^'^'---^:-§--^.

    2. :  Hold onto information until people ore screomihg/or ifc While they are wait- :
     .-:..  Ing. don't tell them when they willget.l^:.Justs'ayv^^
     ^gpi|r^;|^j^ quality assuran^

     .   Ignore peoples'feelings. Better yet, say Uiey arc irrelevant and irrational. It
      ;: helps to add that you can't understand why they are overreacting to such a small
     '''Irtafc^CVf.::;•:::;::•:•               '        '         '"	"	 '"	'"
    4.:: u Don't follow tip.  Place returning phone .calls front citizens at the bottom of your
    '£'• •••"'to- dol'Ust^.pelay. sending out.the.lnibnnaUon.you;iprjpn^ed
      ''                       ••-
    5.   If you make a mistake, deny it. Never admit yo
 ^ |r|6tZ.Jfyou don't know the

'^ii^^:^n^tspeaJcp^tinEnglish.. When explaining technical:^
:; ip^Isibnalijargpa^ Orsimplify so completely rJiat ypu:leaw;outJmportant inf<
:MP:;p'^.Betteryet;:.tto)w;.up:yourhand^             '
                                                                   '..-' • «• , '••'•'•'.-'•'•'•'•'.•'.•'.•'•'.-'•'.\y', •'
                                                                   •undeEriSiE JIM)'.
                                                                           .-.• ::•'•:•!
     ^;b Present yourse(f like a bureaucrat. - Wear^thtte^plecesuitto a town meeting at
       the local grange; and sit up on stage with seven of your collesigues who are:dressed
   Si  Z?e£ay talking to other agendes inwo/ued^ 6r:ptherpeople involved w^
 ->?:::':'^':±::agency^-sp ;the-message, i
      ; If one of your scientists has trouble relating; to people^: hates to do it, and


                     WASHINGTON. C C 204SO
                                            THE AOMINISTBATO*
Honorable Henry A. tfssman
Chairman, Subcommittee on Health
  and the Environment
Committee on Energy and Commerce
House of Representatives
Washington, D.C.  20515

Dear Mr. Chairman:

     On March 24, 1987, I responded to your January  6  letter
pertaining to air toxics and gasoline marketing.   At that
time I said a response would be forthcoming on  your  question
on comparative risk. .  I am now enclosing that reply.

     Thank you for your interest in this aatter.


Please provide a cable comparing risk levels which have supported
regulatory accions under RCRA,  TSCA, Che SDWA, Clean Air Section
112, and othe,r provisions of che Clean Air Act.  -Please explain
any inconsistencies in EPA's views on the levels of acceptable
risk under different environmental statutes, or different provi-
sions within the same statute.


     The two tables below provide comparative information about
cancer risk in EPA decisions under the Resource Conservation ana
Recovery Act, the Safe Drinking Water Act, the Toxic Substances
Control Act and Section 112 of  the Clean Air Act.

     Table 1 addresses the levels of population and individual
risk that led co regulation. 'Table 2 gives information on the
residual risk remaining after regulation.  Although you asked-that
che table include other CAA provisions, the pollutants addressed
under them are not generally carcinogens and their risks are not
readily comparable.

     The tables are illustrative of EPA's risk management actions,
rather than a comprehensive review of all such actions.  While
they include some information about the reasons for decisions, any
judgment about why EPA reached  particular decisions without a
thorough examination of the decisional records would be incom-
plete.  For example, some decisions not to regulate are made with
the expectation of revisiting the issue, later or are elections to
use an alternative regulatory mechanism, rather than conclusions
that regulation is, unnecessary or that existing regulations are

     It is important to recognize that uncertainty,"often great
uncertainty, generally underlies calculations of risk from chemi-
cals in the environment.  As a result, we attempt to be conserva-
tive in estimating risk, preparing what are in effect plausible
upper bound estimates.  That is, the true risk is not likely to be
greater than estimated and could be much lower, even zero.

     Another uncertainty in the tables is that population risk is
based on where people live today.  Future risks may be quite dif-
ferent, especially site-specific ones such as  those from hazardous

     Sources for the estimates in the tables are generally the
Federal Register documents for each decision, although you may
have seen ditrering estimates of the risk from a given chemical
or activity.  The estimates themselves span more than a decade and

lethodologies for assessing toxicity and predicting exposure .have
evolved enormously ever chis time, as have the assumptions and
data we use in applying chese methods.   Because exposure pathways
differ among che environmental media, and for various program
specific reasons, there are also differences in methodologies,
data and assumptions across programs.  As a result, one should be
cautious in making comparisons among the estimates in the tables.

     Over  the past few years we have moved vigorously to  assure  .
the quality of our risk assessments, and their consistency.  These
efforts  include  creating  institutions such as  the  Risk  Assessment
Forum  to address technical  issues,  developing  risk assessment
guidelines, developing consistent databases about  risk  and  other
activities.  For example,  our  newly developed  Integrated  Risk
 Information System  (I&IS)  will provide  the Agency's  current view
of the toxicity  of any chemical  in the  system.

      While we  are  conducting a broad range  of research to increase
 our understanding  of environmental risk,  much uncertainty will
'remain in the  short run  and some will endure  no matter how much
 research we  do.   We  must inevitably make decisions to protect
 human health and the environment in the face of uncertainty.  This
 alone makes  it very difficult to conceive of using-some "magic
 number" of acceptable risk as a guide in our decisions about when
 and how much to regulate.  Moreover, the very concept of accept-
 table risk in risk management  decisions is a complex one.   Part  ,
 |bf the complexity is shown in the  tables:  we consider both indi-
 vidual and population risk, rather than simply  the  individual risk
 you cite  in your letter.

      A second kind  of complexity is implicit  in your question:  we
 must  consider how the environmental statutes  differ  in their
 treatment of  risk.   For  example,  both  FIFRA  and TSCA explicitly
 provide  for weighing human health risk against  the  economic and
 other benefits  of. chemical use.   The  Safe  Drinking  Water Act
 allows  consideration of  costs and other  factors in  setting contam-
  inant levels  (MCLs),  but requires that goals (MCLGs) be based on
 health risk alone.   Complexity arises  not  only from differences
  in the degree to  which  other factors  can be  considered with risk.
  buc also in how and when such considerations can be included in
  decisions under the various statutes.

       Third,  we seek to  protect against many different risks:
  lead poisoning, asbestosis. a wide variety of  cancers, damage  to
  property and natural resources, reduced recreational opportunities
  and many purely ecological risks.  It is very  difficult to compare
   these quantitatively.  Our recent comparison of  the risks
   addressed by EFA programs (Unfinished Business:  A  Comparative
   Assessment of Environmental  Problems) defines  four broad  cate-
   gories of risk (cancer,  non-cancer, ecological and welfare)  rather
   than attempting to weigh  very different kinds  of risks  against one


     Our ability to reduce risk can also be a factor  in  deciding
whether a given risk is acceptable.  Where appropriate,  we  con-
sider  factors such as technical feasibility, control  costs  and
benefits, and the availability and impact of substitutes.   For.
example, our decision to phase down the amount of  lead in gasoline
from the standard of 1.1 grams/gallon set in 1982 was basea upon a
1984 comparison of increased refining costs with benefits in  the
form of reduced vehicle maintenance, better fuel economy, reduced
emissions of HC, NOX and CO, lower levels of lead  in  children's
blood, and improvements in adult blood pressure.

     In management.decisions about environmental risk, EPA weighs
considerations such as those above, and others which  apply  to a
given  case.  We assess the risks as objectively as possible,  using
appropriate quantitative and qualitative information  and taking
into account the weight of the underlying scientific  evidence.  We
do this both to assure full understanding of the decisions  facing
us and to provide some consistency among the Agency's actions.
Nonetheless, risk management decisions will show variations in
what level of 'risk- is accepted both because of the need  to con-
sider  factors other than risk and because assessment  of  risk
itself is complex.

     Reviews of past risk management decisions can show  how the
risks addressed by those decisions vary, as do the tables here,
but such historical reviews may not show which factors were deter-
minative, how heavily they were weighed or even the full set  of
factors considered.   Nor can they answer the question of precisely
what risk will be acceptable in the next risk management decision.
There will inevitably be some application of judgment and,  there-
fore,  limits to the usefulness of narrow decision rules or
numerical risk targets.

     We are moving to make better risk management decisions by
improving the quality of our risk assessments,  advancing the
science on which they are based, and increasing consistency in
interpreting scientific  information and balancing it with other
factors.   We also seek to do better at informing the public about
our decisions and how we reach them.



1. Maleic Anhydride
2. Fugitive

 vinyl  Chloride

 l.  Emissions  from
   EDC-VCM plants
  :  Emissions from
   ?VC plants
 Inorganic Arsenic

 1. Low Arsenic
   copper smelters

 2.  Glass

 Ethylene oxide


Not regulated
1984 (Risks do not
warrant Federal
reglatory program)


Not Regulated
(Risks do not warrant
Federal regulatory
 1976  (Risks not
 explicitly considered)

 1976  (Risks not
 explicitly considered)

 Regul ted

 Intent to List

 Intent to List

 Intent to List
                               Population  Maximum
                               Risk        Individual
                          (cases/yr)    Risk

.  .3








Regulated (as
calculated in 1979)
                                                             > 6X10-4
Ln school labs
Addressed by CPSC
.isting of Haz-
irdous Wastes
Standards for
Treatment, Storage
and Disposal
Used Oil
corrective Action
Location Standards
Land Disposal Bans
organic Toxicity
Subtitle D
Mining Waste
 (Chemicals are added
to list based on risk)
(Risk information is
check reasonableness
solutions proposed)
Pending proposal
Pending proposal
Pending Proposal
Pending Proposal
Pending Proposal
Pending Proposal
Pending Proposal
Pending Proposal

used only to
of technological
> 10
> 10
> 10
< 5
< 5
< 5
10-5 — 10-6

10-4 — 10-8
10-3 — 10-6
10-3 — 10-8
10-4 — 10-8
10-4 — 10-8
10-5 — 10-8

         2  Risk Levels for Regulator/ Decisions
                                                       Residual Risk
   Risk      Population  Maxisur.
   Avoided    Risk       -Ir.divii-.
fcases/vr)(cases/yr)   Risk

A: Maleic Anhydride
3. Fugitive

vinyl chloride
A. Emisssions from
  EDC-VCM plants
    missions from
    C plants
Inorganic Arsenic
A. Low Arsenic
  copper smelters

3.  Glass
Not to regulate
1984 (Risks do not
warrant Federal  •
regulatory program)

Not to regulate       —
(Risks do not warrant
Federal regulatory program)
 Regulated          .  .5
1976 (Risks not
explicitly considered)

Regulated            14
1976 (Risks not
explicitly considered)


2X10-4 —





Regulated  (1979)
Recalculated with
new data
in school labs
Addressed by CFSC


 Differences Between  Expert  and  Public
 Rankings  of  Environmental  Problems
      Q EPA published a report, Unfinished Business: A Comparative Assessment of   -
        Environmental Problems, in February 1987.  The report examined the risks of
        cancer, non-cancer health effects, ecological effects, and welfare effects posed by 31
        different environmental problems.  Stimulated by this report, the Roper Organization
        polled nationwide samples in December 1987 and January 1988 to find out how the
        public ranks the seriousness of essentially the same list of environmental problems.
      Q The two groups addressed slightly different questions.  The EPA experts only
        looked at the tangible aspects of the risks (cancer incidence, etc.), whereas the
        public was not similarly constrained and could consider intangible effects in ranking
        overall concern.

Dttferencas  .

      Q The most striking difference is that the public ranks active and inactive hazardous
        waste sites as #1 and #2, whereas the EPA experts ranked them medium/low in the
        various risk categories listed below.

      a At the other end of the scale, the public ranked indoor air pollution, including radon
        and consumer product exposure, and global .warming very low, while the EPA
        experts ranked* there (]uiie high.

      a Important points of agreement included  pesticide risks  and worker exposure to toxic
        chemicals  (relatively higher risks and higher public concern) and contamination of
        drinking water as it arrives at the tap (relatively medium in both cases).

      Q In general, EPA's legislative priorities correspond more closely to public perceptions
        than to expert assessments of risk.

Why the differences?

      9 The subject is vast, and it is hant for anyone to have fun knowledge of it.
"Difference* Between Expert and Public Ranking* at Environmental Problems* prepared by the Environmental Protection Agency: Office of
Policy. Planning, and Evaluation.

       Q Research has shown that people often overestimate the frequency and seriousness of
          dramatic, sensational, dreaded, well-publicized causes of death and underestimate
          the risks from more familiar, accepted causes that claim lives one  by one.

       O The public perception of hazardous waste is driven by drama and  dread. The
          intrusive, involuntary nature of the risk, the fact that slow-moving ground water can
          stay polluted for a very long time, the presence of as identifiable "scapegoat." and
          the difficulty many people have in seeing an overriding benefit to  having a
          hazardous waste site nearby are also important The EPA report noted that in
          certain locations hazardous waste does pose a very serious risk, but relatively few
          people live near enough to the sites to be directly affected; other environmental
          problems simply cause more damage to more people and ecosystems.

       Q Indoor air pollution, including radon and consumer product exposure, and global
          warming are risks to which everyone is exposed.  The risks are not dramatic and
          come from familiar, diffuse, generally accepted sources.  It is usually difficult, if
          not impossible, in these cases to finger a "scapegoat"; and the benefits from the
          problem-causing substances  are clear.  Some of these problems are also not well
          understood by many members of the public.


       a Public policymakers and all  those involved in discussing environmental  problems
          and risks with each other and with the public need to recognize how people may
          react to the problems and risks, to understand why the risks hare been assessed
          technically as high or low, and to tailor policies and communications to
          accommodate differing perspectives. Experts should avoid thinking of the public as
          "wrong" or "irrational," when in fact the public may simply be following a different
         rationale.                                             •                     '

       Q The differences raise an important issue for a democracy. Put crudely, should a
         democracy focus available resources and technology where they can have the
         greatest tangible impact on human and ecological health and welfare, or should it
         focus them on those problems about which the public is most upset? Put more
         pragmatically, what is the proper balance?   -

For Further Information

       Q Contact die Office of Policy, Planning, and Evaluation or the Office of Policy
         Analysis (202-260-4012) or (202-260-4012).
"Difference BOUMM Expat tad Public Rukiap of Envwomneaul Problem*" prepared by the Environmentl Prmeoioa Agency: Ofii.r
Policy. Planniaf. and Evaluation.

                           Perceived Seriousness of Some
                                Environmental Problems
    Active KaziKtous Wane Sites
    Abandoned Hazardous Sic**
    Nodear Accident RadUtkm
    Underground Task Leaki
    Pesticide Residue
    Industrial Accident Pollution
    Faoa RttfrCtt Was motion.
    bdnnrial Air PoflotjoB .
    Otme Layer Deanictioa
    Occaa. Coastal Waur
    Sewage PlMt Water PoilotiM
    OflSpifli; Token. Rigs
    Acid Rait
 aMr/vr   ""5"

   Gesfttc Alter. Damage
   Nofl-Haurdout Warn Sites
   •Greeatoue- Effea
   Indoor Air Poflauoo
   loooor Radoe Air PoOatioa
   Microwave Oven Radiation
                                     Don't Know

                                     Somewhat Serious
      80        100
Not Too, Not at All
Very Serious
"Differencei Betweea Expert and Public B*"tiTt* of Eavjronmenul PtcMemi' prepared by the Eo
Policy, Piaaaiag, aad Evaluation.
                         i Agency:  Office of

         How EPA Experts Rank Environmental Risks—Highlights
Overall High/Medium Risk
Q "Criteria" air pollution from mobile and
  stationary sources (includes acid
Q Stratospheric ozone depletion
a Pesticide residues in or on foods
Q Runoff and air deposition of pesticides
High Health; Low Ecological and
Welfare Risk
Q Hazardous/toxic air pollutants
a Indoor radon
a Indoor air pollution other than radon
Q Drinking water as it arrives at the tap
Q Exposure to consumer products
a Worker exposures to chemicals
Low Health; High Ecological and
Welfare Risk
Q Global warming
3 Point and nonpoint sources of surface
  water pollution
o Physical alteration of aquatic habitat
  (including estuaries and wetlands) and
  mining waste
Overall Medium/Low Risk
(Ground-Water-Related Problems)
Q Hazardous waste sites—active (RCRA)
a Hazardous waste sites—inactive
3 Other municipal and industrial waste
a Underground storage tanks
Mixed and/or Medium/Low Risk
3 Contaminated sludge
3 Accidental releases of toxic chemicals '
3 Accidental oil spills
3 Biotechnology (environmental releases
  of genetically altered materials)
SOOKC: Unfiniihed BWUMM: A Conpmuve Assessment of Environmental Problems (EPA 1987)

               Lethal  Legacy  of Lead  Poisoning
Long After a Battery Plant Shuts Down, Contamination Lingers in Soil and Bones

       rom UtOmmg tO 1*Bgr^i {Of 14 nUIIS
              residents ctf this nofThpsst
       the iOCSt ugh iukM wt
tests ••.bey feared would uncover a locg-
burir  prjlem.
  M .vjig slowty tea grcananmi to d**f»
«»r, they filled ant health binaries, five
btool  and were  tobiected to * battery  p^^nm^ MI^^W^ t^ rewjta:
One third of the 200 residents be tested bad
elevated levels ot lead a their bodies. Many
of item were children.
  Far  year*,  residents  had  wondered
whether the aid Man* Batten *  Eva?.
        was poUunng their town. Black
doudat^Bfct tad beached tan the bmt-
tery (V^^B otsnt and wafted over nesriy
MMtfwkUlwBwBwBwl*^ J ri i  ....... i i* •  itul -*•.•*• *
throofh ckthmg hugm* out t
found ttt aeirtf ytids aad streets in 1975
                                                                        formed Halt Enviioonentai Lead Foliation.
                                                                        HELP, wtrich persuaded several of the a*
                                                                        tiau'* leadtng experts in rhiidhoori lead poi-
                                                                       '«0>at, indudui( Rosen, to counsel them.
                                                                        Toe group rented a van and in late 1989
                                                                        suited  ferrying  people  120  miles to
                                                                        Rosen'* clinic in the Bronx, where be w»s
                                                                         1 really didn't know what to T~r* re-
                                                                        called Rosen, tua I was shocked.' More
                                                                        than a third of the 75 Throop- residents
                                                                        Rosen bad-elevated levels of lead in their
                                                                        bones. He decided to go to Throon.
                                                                         List June. Rosea and fife leehnioans
                                                                        screened an yH**"1!!  125 y******«w« here
                                                                        aad cooducted aeurciopol and learning-de-
                                                                        velopment >••*«
                                                                         'the preliounary results indicate that a
                                                                        highly sigQificant  percentage of residents
                                                                        across s wile age.range bave ckaroit et-
                                                                        kdeoce of ^**^ exposure that occurred ear*
                                                                        tier ia their lifetime,' he sari.
                                                                         Those with the highest level ol lead ex-
                                                                        posure had grown op during the yean the
                                                                        Marjot  plant was  operating. Nearly two
                                                                        thirds at the teenagers who were tested had
                                                                        high tod levels.
                                                                         Oisas Schortt.  16. is among them. A)-
Bom.  wtm eoid tbcm tibar fcarm were
       chat SBflit atteet

  Lead is a hiajilf tone BUttctiaL OuldRB

metii cso daou|e the fiuvuf
and *****•«**» to  detect* and beooM the
HiroU flt KM pOttflflAwm DM OfefM EOF M
            hen ven UBBVCJUI CB fo^

  •We bad a
had been ptaymg ID t beenty
X-ray boas lead sadist.
joo have to took*
  And  that is  where the
            The SLotMii
     big. framsi Vieunan borne
Marial site in 1979. "Be dU it
was aacsi a btg place and we had «
famdy»* Susstt Schorls recalled.
  They knew abont Marjoi'*
the oast, about the ksd that had been.ioond
in tb»soi| of neighbors' yards bsctvk 197S.

Jata  and Owns, had  been amoasj the. 200
dudreD a towa who, M psrt of the ctata's
|tLHMl «•>•*• !*••• w^^^^l^J KM
Djooa WEHB m iCfeaiM DO
                                                                                     EPA foond kwls ol MM*
                                                                                   rpsr nuuiDB H Throopi ^"'Hff*^

                                                                         .her ^isiBmi tree^hsdfd fard.
                                                                           The Mazpi site and the snmBndnif ares

                                                                         ml Sajestod law. Beeaant in 1988. the
                                                                                 the ai honwswere emmed to
                                                                        nroUenw. Rosen's tests found that Dana
                                                                        has 57 pans per munea ol lead ia her banes.
                                                                          Then are no liifaiMiii yet for how HUB h
                                                                        lead m the bones poses a threat, but Diana's
                                                                        level utUytiV  was ir-imi'ofaie. Todd. the
                                                                        Uniersfcy oi Maryland researcher, has
                                                                        (ooad m average of 30 parts per million ia
                                                                        lejd"AiueJte? wmiutis 01 Europe.
                                                                          Lead particles are  generally inhaled or
                                                                        ingcBed. then fad their way iota the blood-
                                                                        •SI^^^M^ A«J  .B-jiii  fImi_l_H^ m.k^f**±**t S^B *4kA
                                                                        mwiu BHI  w&n> amiiy wMPwrtmi of mn
                                                                        bgaetv Oftoa  locked m the boae* chiey do

                                                                              of the conn on be releaaed under
                                   waftdedsnd totaltr uesaie. Several months

                                     Thai desflu&» now esttnabfid at SIB oisV
                                   &OBV is beioi paid far by the Gould Corp.
                                   which boafht the Msqai ate after the phot
•We winted tuvai* and «e dido't tnat
                                                thexe «a^ no hcatt.. proiv

                                         ol ttttt apptanTBd to uipport that

              TlWUJUIUf, (BJCMB hVfV

               But the oeni it&gen n
the takjoi oDt)r 30 to 45 dm,
  "NiM^fire percent af the body burden
ol Ica^^^feond IB the booeii* nid Andrew
Todflllesnr of medial abyacs at the
                                      In 1976. after repeated fiohbaas. tte
                                    deptrtment ordered Majjoi to shot down in
                                    lead meter. In 1982. the emane pant WM
                                    dosed for good. That seemed to b* Ute end
             the federal E&viniiiiie&tai
Piumjioo Aajency cane to town* tested thfi

that the yirta of the Scbora home and 40
AoooniiBf to tfag& £PA gtttdfhue, aid with
   than 50 puta. per nhinosi tt ted vifbt
                                   dnD did flot tweu any cwvatBd
                                     But tfaia ttDB oiany peopw hen CCIMM
                                   to bdie*< t^uythipy WM ait hgfaL

                                   •^^ fcairll k.H^^^ ^^Aa^ i. I'.i • II • I	I	
                                   ana DncK Bones wnere uMtttMnM mues
                                   predosmaie* was not a likely candidate to

                                     But the shock of bemg declared a Suner-
                                   fund site a doten yean after the sate had
                                   said (bevs* wss no proUeei webbed heavily
                                                                                      lead 4 rncued a a boo& •
                                                                          ttukeu, tf tfae wOdtviduat is betiiiUen for a kaif
                                                                             oc » beocsDe jutEen boos oxaae*
                                                                              yHrrii'M rdeaae could ^^fir IE Dta&st
                                                                              to b^e a  bahf , Roan  wuued tte

                                                                          souoe QV ***"**"* tor the fetus* uieife • a
                                                                          tnt flt esaeDtBUiy pocaonm( loe ietoa«
                                                                            Roaeoadviatd theSdjotnfmsiJy to moa>
                                                                          jtor Dimi's hJootHead teveb aod kadnef
                                                                          fiinrtion i& future cfaedtupay becmag lead
                                                                          oa eaatfy trnpair the btoen.
                                                                            PcniMTtvama offidaia bave link to say
                                                                          about Throop. "Our understanding 

                    Preparing for the Interview
                           Paul Lapsley
 1.   Learn who your  audience is and what issues they're concerned
     about.  When the journalist or reporter calls to schedule the
     interview there are several items you should discuss with
     them in setting up the interview:

     o    Ask them  how ouch they know about the issue.  Take this
          opportunity to give them a brief background or if they
          don't have time, offer to send them some written
          materials; if they don't have time to discuss it,
          you'll know that the only opportunity you'll have to
          inform them and their audience will be during the
          interview.  That information, by itself is important.

     o    Learn from the reporter what issues their audience is
          concerned about.  Often this will give you an insight
          into what issues you need to be prepared to deal with.
          If the reporter doesn't give you any guidance, it's an
          opportunity for you to suggest areas that you will
          cover in  the interview,  if the journalist has little
          knowledge on the topic they will welcome you outlining
          how the interview should go.

     o    Learn how much time you'll have to explain the Agency's
          position.  This will help you determine how to make
          your presentation.   If the journalist tells you that
          you're only going to have a ten second spot on the
          evening news, that will motivate you to get your
          message out clearly and succinctly.  On the other hand,
          if the interview will be a dialogue that will come out
          in a Questions and Answers session for the audience,
          then you'll have an,opportunity to provide more
          extensive explanation to a series of key issues, which
          you will be able'to frame for the journalist.

2.  Decide what it is you want to convey and how much time you'll
    have to do it.   Think through the logical explanation of how
  .  the Agency  arrived at its current position and what actions
    it's taking to deal with the situation,  both now and in the
    future.   Be prepared to answer criticism that the Agency
    should have known the hazards earlier and taken action more
    quickly.   At the same time,  be prepared to respond to
    criticism that the Agency is overreacting and that the hazard
    doesn't really exist.   You must present a dispassionate and
    reasoned approach to dealing with a hazard that has been
    established through credible information.

3.  Learn what others are saying about the risk so that you can
    defend the Agency's position.   We will frequently be
    presented with statements that environmentalists are making,
    or statements from the chemical industry, and asked to


    reconcile those statements with the Agency's action.  Be
    prepared to respond with a logical explanation of why the
    Agency's action is most appropriate in light of available
    information and why environmental or industry actions are

4.  Be familiar with the various exposure routes that could lead
    to risk, and state what exposures (e.g., groundwater,
    inhalation, homeowner,  etc.) present risks of concern and,
    just as importantly, those exposures which are not reasons
    for concern.  Know what assumptions have been used in the
    risk assessment.  Be prepared to explain that the Agency has
    used conservative assumptions in estimating risks and what
    they are.  It's important to comment that conservative
    assumptions are used as a prudent approach to protecting
    public health and the environment, however we expect that
    actual risks would be less.

5.  Know what the economic impacts will be.  Frequently the
    audience is more concerned about the impact on their economic
    situation then they are about the risk implications.  You
    must be able to assure them that the Agency has considered
    the economic implications, and believes its action is
    necessary in spite of those impacts.

6.  Prepare yourself to represent the Agency, regardless of your
    own position.  Your audience will be assuming that you are
    the spokesperson for the Agency.  Consequently, regardless of
    your support for the Agency's action, you must be prepared to
    present the Agency's position and defend it, without calling
    into question any aspect of the decision.  Any concerns you
    may have should be discussed internally.

                    AT THE NATIONAL CONFERENCE

      The point of  all this is  that most.of  the information^on
 risk  assessment is funneled through the media  - local news
 sources  more than  national ones.  The national news has a half-
 hour  every night to tell you everything of  consequence that
 happened on earth.   Risk assessment is  very rarely part of  that.
 The nightly national news  broadcast is  usually a recap of the
 hits,  runs,  and errors of  the  day.

      Most local reporters  have little or no knowledge of or
 background in technical matters.  Yet when  something happens,
 they  are sent out  on a story.  In 90 minutes or so they must
 become instant experts because they have got to make the .air that
 night or the deadline for  the  newspaper.  Most of  them tend to
 parrot things that are told to them.  Very  little  local news is
 analytical,  and when it is,  it tends to be  analytical in the
 sense of "this.is  what one side says, this  is  what the other side
 says."   As I said,  we are  required to be instant experts, but we
 rarely investigate further the story of the day. .  There are big
 incidents,  but there is. very little follow-up.

      The media's posture with  regard to risk is primarily
 reactive,  which is  to say  that we tend  to come in  after an
 incident involving risk.   We look primarily for victims: victims
make  good television, good print.  We also  investigate the
aftermath of incidents, assisted ,by critics.   We like critics
because  they can look at some  event and say that if something had
happened or had not happened,  there would clearly  have been a
different outcome.   Rarely do  we take time  to  look in advance at
things that  might  happen.

     We  also often look for officials,  for  two reasons.  First,
they are people  in  authority,  although  they are in fact rarely
authorities.   Indeed, they are rarely capable  of even commenting
on risk  issues  because of  their sensitive hews nature.  Second,
we look  for  officials because  we want to affix blame.  If we need
someone  to blame, we usually choose an  official; he or she  can be
portrayed as  asleep at the  switch, so to speak.

     After interviewing officials, .we do a  thing called Man on
the Street -  rwhat  do you  think about that?"  We go out and get
three or four interviews,  10 or 15 seconds  from one'person  or
another,  and  that  is  the local news.

     Now if  that sounds critical, it is meant  to be.  We are
reactive, and we are  allowed to be that way.   You  have allowed us
to go .off half-cocked on a  variety of issues.  You have not
corrected us; you have not  given us advance information.  The
result is exactly what you  see in the news media today.  What you
see is reaction  rather than analysis.  When you do see analysis,
it is not. very good analysis.  The media are highly speculative.
For instance, the media are now trying  to figure out what

From Risk Communication; Proceedings of theNational Conference
on Risk  Communication.  Edited by J. Clarence Davies, Vincent T.
Covello, and  Frederick W. Allen .(The Conservation  Foundation,

      -                       63

happened to the Challenger before any of the experts have
collected its parts.  That is what -the public demands from us.
We are always trying to fix blame.

     The reality of the situation is that most viewing or reading
audiences are not very attentive.  They do not pay much attention
to what the media are saying.  We are generally background noise
for dinner.  We are required not to be terribly lengthy in our
comments because we tend to bore people.

     Why is that important?  It is important because it  .
encourages us to look for the smoking government, the body count,
or the rocket's red glare.  You have seen it all a hundred times,
and you will see it a hundred times again.  Therefore, you have
to educate the media; you have a responsibility to become a
participant.  If you let us keep going the way we are going,
everybody is going to survive, but things are going to become
more difficult as our society becomes more technological.

     You have to understand the risk that you are communicating,
but, more importantly, you have to understand the media.  You
have to talk to us in advance.  You have to involve the public
early.  If we do not pick up on you information often enough,
then you have a legitimate basis for a complaint.

     Furthermore, you have to speak to us in English,  what is 10
to the minus seventh?  What is one part per billion?  I may not
understand the concept of a billion, but when you explain that
one part per billion is one second out of 32 years, that does not
seem to be much dosage or much time to be' 'exposed to something
that is considered to be so awfully dangerous.  There are a lot
of extremely dangerous things you can be exposed to for one
second out of 32 years and not suffer any great consequences.

     So, as scientists, regulators, and policy makers, you have
to figure out what the media do, how they work, and how to make
them work for you.  You have to participate.  That means that you
must be aggressive rather than reactive.  You must help people
understand things rather than defending a company or an agency
from criticism.  You have to learn to deal with media inquiry, to
supply information in advance and consider the medium.  If you
are dealing with television, you do not want to have a group of
people sitting up here talking.  You want to be able to show
pictures.  If you are dealing with radio and print, you need to
paint pictures with words.

     You have to learn how to be a source of information that is
trusted.  You have to decide who should talk to the media.  Very
often the media contact is a public relations person who either
does not understand the issue or is allowed to speak only the
party line.  When something bad happens, the person who made the
decision should take the heat because the heat will go away that
much more quickly.  It is crucial to understand how the system

works.  You have to know how the media format a newscast, a
newspaper, or broadcast.  You have to understand who the players
are, on the screen, on 'the air, in print, and even more
importantly, behind the scenes.  You have to understand how to
gain access to the nonnews media out there:  the feature editors
of the newspapers, the morning television shows that you would
never think anyone would be interested in, although they have
vast audiences and 8 or 10 minutes of unedited time that is
almost never utilized.  There are great media wastelands that you
are not taking advantage of:  the weekends, for example.  In most
major cities, the most watched newscasts are on Sunday evening.

     Finally, you have to understand that if you have a news
event planned on certain days or when certain types of events
occur, you must cancel it.  The situation with the Challenger is
a case inpoint:  if you have a conference or press briefing
planned for this week, you should reschedule it, because it is
unlikely to be covered.              •

     If you understand how the media work and demand a higher
degree of participation in the system, everything will improve.
Then, if you see a pattern of abuse, you have a duty to make
complaints that may attack the broadcasting license that is
damaging your industry or your profession.


                         Do's AND OON'TS FOR SPOKESPERSONS
       The following list contains a checklist of DOs and DONTs to review before you
    agree to an interview.
    1) DO ask who will  be asking the

    2) DO ask which topics  they want to
DONT tell the news organization whicnx
reporter you prefer to work with.

DONT ask for  specific questions  in.
    3) DO caution them that you are not
      the right person to interview if there
      are topics you cannot discuss (due to
      lack of knowledge, litigation, trade
      •secrets, etc)

    4) DO ask how long the interview will
      be and what the format will be.
DONT insist that they promise not to
ask about certain subjects.
DONT demand that your remarks not
be edited.
    5) DO ask who eise will be interviewed.
DON'T insist the reporter not interview
an adversary.
    Prior to interview/news conference:

    1) DO obtain accurate information and
      be completely honest.

    2} DO decide what you want to say, and
      check to make sure you  have the
      appropriate information.
DONT try to fool the reporters and the

DONT believe you know it all
Reprinted in  Risk  Communication Student Manual,  edited by  Erin
Donovan,  Vincent Coveilo, and John Slavick  (Chemical
Manufacturers Association, Washington,  DC 1989).

During the Q & A:

1) DO be honest  and accurate.   Your
   credibility depends on it.

2) DO stick to your key points.

3) DO lead. Take charge.

4) DO raise your key messages.

5) DO offer to find out information you
   don't have  if a question is  raised
   about it.

6) DO explain the subject.

7) DO stress the facts.

8) DO explain the context.
9) DO be forthcoming to the extent
   you've decided upon beforehand.
10) DO give a reason if you can't talk
  about the subject.
DONT lie.
DONT improvise.

DONT react passively, but DONT be
overly aggressive or rude either.

DONT dwell on negative allegations.

DONT guess, because if you are wrong
your credibility will  be shot.
DONT use jargon.

DONT discuss hypothetical questions.

DONT assume  the  facts speak  for
DONT decide to reveal something that
is  confidential without considering its

DONT dismiss a question  with "No
il) DO sate your points emphatically.       DONT ask reporters for their opinions.
12) DO correct big mistakes by stating
  that you  didn't give  an adequate
  answer and you would like a chance
  to clear up the confusion.
DONT demand that a botched answer
not be used.


 13) DO remember the media are inter-
   ested in "what? when? where? who?
   how? and why?"

 14)  DO stress any heroic efforts, by
   individual employees.

 15) DO emphasize what is being done
   to correct the problem.
 16) DO state your conclusions first, to
   get  your main  points across, then
   back them up with facts.

 17)  DO have  available  information
   relating  to company processes, raw
   materials,   and   chemical  inter-
DON'T be afraid to say that you don't
have  the answers to "who?  how?  or
why?  at the present time.

DONT stress any individual errors  or

DONT  estimate  monetary damages.
costs  to the company, insurance cover-
age or level of interference with compa-
ny activities.

DONT let your message get lost in a
morass of detail.
DON'T hesitate to refuse to give propri-
etary information.
18) DO try to be as open with the me-
   dia as possible.
DONT give  one  reporter  exclusive
Alter the Q & A:

1) DO remember, what you say is still
   on- the record.

2) DO remember, it's all on the record.
3) DO be careful around microphones
   and tape recorders.
DONT assume  the interview/confer-
ence is over.

DONT insist that some comment will
now be  put "off the  record."

DONT assume that a microphone is
ever off.

 4) DO correct any mistakes you made
    in the Q & A.

 5) DO volunteer to get additional infor-
    mation reporters need.
 6) DO tell reporters to telephone if they
    have any questions about something
    that you said.

 7) DO volunteer to  be available if a
    reporter wants to go over something
    with you.

 8) DO call reporters if stones  appear
    that are  inaccurate,  and  politely
    point out what is wrong.
DONT let sleeping dogs lie.

DONT refuse to talk any further with

DONT ask "How did I do?"
DONT ask a reporter  to show you a
copy of the story in advance of publica-
tion or broadcast so you can correct it.

DONT call the reporter's boss to com-
plain  without first speaking with  the
                      Five Most Frequent Interview Failures

 1) Failure to take charge. The spokesperson must be a leader. His/her role is not just
   there to answer questions, but to disseminate information.

 2) Failure to anticipate questions.  Don't just concentrate on assembling the factual
   details.  Prepare for obvious questions.  Remember, the public wants to know "Is it

3) FaSure to develop key message.  This is you opportunity to communicate with the
   public  Make  sure you can take advantage of it by having your organization's
   message prepared and ready for use.

4) Failure to stick to the facts.  Speculating or answering, hypothetical questions can get
   you into  trouble.  Avoid "what if questions  by confining your answers to what is

5) Failure to keep calm. By not letting questions get under your skin, you will show a
   willingness  to  cooperate with courteous journalists and convey an impression of
   candor.  Keep cool.

 KskAnatytu, Vol. 10, No. 3, 1990
 What  Do  We Know  About  Making Risk  Comparisons?
 Emilie Roth,1 M. Granger Morgan,1-3 Baruch FischhofT,3 Lester Lave,1 and
 Ann Bostrom2
                           Rteavtd April 5, 1990
                           The risks of unfamiliar technologies ire often evaluated by compiling them with the risks of more
                           familiar ones. Such risk comparisons hive been criticized for neglecting critical dimensions of
                           risky decisions.. In  t guide written for the Chemical Manufacturers Association, Covello « a/."1
                           hive summarized these critiques and developed i taxonomy that characterizes possible risk com-
                           parisons in terms of their acceptability (or objectionableness). We asked four diverse groups of
                           subjects to judge the acceptability of 14 statements produced by  Covelto el aL  as examples of
                           their* categories. We found no correlation between the judgments of acceptability produced by our
                           subjects and those predicted by Covelio a aL.
                           KEY WORDS: Risk companion; risk ojmmunieition; risk perception.
     A tempting way to describe the risks of hazardous
 technologies is by comparison with other, better known
 risks/2-3) such as: the cancer risk of living at the bound*
 aiy of a nuclear power plant for 5 yean equals the cancer
 risk of eating 40 tablespoons of peanut butter (due to
 aflatoxin)/3* Despite their appeal/4' such comparisons
 have come in for considerable criticism/*-71 There are
 two major thrusts to this criticism. One is that  these
 comparisons reduce risks to a single dimension (e.g.,
 loss of life expectancy), whereas many risks are multi-
 dimensional. As a result, risks are not fully represented.
 The second thrust is that risk comparisons are used not
 just to communicate how large risks are, but also to
 persuade listeners regarding  how large  risks should be
 (e.g., if you are willing to eat 40 tablespoons of peanut
 butter over the next 5 yean,  then you should be willing
 to live near a nuclear power plant). Such implicit rhe-

 'Wesunghoiise Science and Technology Center, Hratergh. Pemsyl-
 vinii 1J235.
 "Department of Engineering and Public Policy, Canegie MeOoo Uni-
 venicy, Pittsburgh,  Pennsylvinu 15213.
 To whom correspondence should be addressed.
torical arguments ignore critical  elements of people's
risky decisions, such as bow voluntary the choices.are
and what benefits they an expected to provide. Because
people perceive risks in multiattribute terms, the fact that
a risk has a low value on a single focal dimension (e.g.,
estimated fatalities in an avenge year) does not imply
its acceptability.w As a result of these logical and ethical
flaws, it  should not be surprising that risk comparisons
have provoked anger and mistrust (responses that can
only be aggravated by skepticism about how far the risks
estimates themselves can be trusted).
    In order to help chemical industry spokespeopte avoid
these pitfalls, Covello a ot(1> developed a manual ad-
vising plant managers on how to present risk compari-
sons so that the public wfll perceive them as useful and
legitimate. Their manual has been published and distrib-
uted widely by the Chemical Manufacturers Association.
    The  manual represents a significant contribution to
the tisk communication literature. It provides, for the
first time, an analysis  of the different  ways that risk
comparison statements have traditionally  been em-
ployed, and offers a framework for evaluating  them.
Covello ft aL enumerate 14 commonly used types of
risk comparisons, which they then group into five cat-
egories, ranked according to their predicted acceptability
                                                                                       01HO Ssony to «ok

to lay people (see Table  I). The manual recommends
that spokespeople select the highest ranking risk com-
parisons whenever possible, and use low ranking risk
comparisons with caution,  alert  to the possibility that
communications using them could backfire.
     Because the research base is thin, Covello et aL 's
ranking is based on their accumulated experience and
intuitions. Because of its potential significance for guid-
ing risk communication, their proposal warrants empir-
ical evaluation. The present study focused on how well
Covello  et  ai's ranking  predicted lay people's judg-
ments of the acceptability of risk comparisons. Its results
provide us  with a point of departure for a throretical
analysis of  Covello ft aL's proposal.

     The  Covello a aL  manual  provides concrete ex-
amples of their 14 categories of risk comparisons, set in
the context of a specific scenario: A manager of a chem-
ical plant in a small town is faced with the task of com-
municating to the community about the risk of a chemical
produced by the plant (see Appendix). We asked several
groups of laypeople to evaluate the acceptability of these
     Such an evaluation  requires an operational defini-
tion of "acceptability." The definition intended by Cov-
ello et aL is suggested by the following quotation.
   Tile highesbranking cofnpsnsons m assumed to be those that
   put the lean asm on the  mm relationship between * pint
   manager ind lie public. Thews comparison* tod to strike even
   skeptical listeners as relevim, appropriate, and helpful infor-
   mation. The lowest-ranking comparisons, on the other hand,
   arc those that have BO intuitively obvious claim to relevance,
   appropriateness, or helpfulness. Suca comparisons are more
   likely to be seen as manipulative or misleading— ibat is, as
   efforts to preempt judgments about the acceptability of the risk.
   (P. IT)
Thus, there are several distinct elements that contribute
to acceptability.  As a result, we devised seven rating
scales that seemed to tap different elements of Covello
a aL's definition of "acceptable." These scales appear
in Table n. Scale  1 asks about how clear and easy to
understand the statement is. Scales 2 and 3 consider the
perceived relevance and helpfulness of the risk compar-
ison. Scale 4 ask  whether the .isk comparison seems
misleading, in the sense of underemphasizing or over-
emphasizing the  risk. Scales 5 and 6 ask how the risk
comparison will affect public trust in the plant manager.
Scale 1 provides  an overall measure of acceptability, by
asking whether die  statement should be  included in the
plant manager's talk.  Our subjects' response should re-
veal how these alternative criteria are correlated with one
another as well as with Covello a aL *$ predictions.

2.1 Method
     9  '

2.1.1. Paridparas

     Four groups participated in the study: (A) second-
year graduate business students (#» 13); (B) members
(or their spouses) of a suburban garden dub from a raid-
                           TaM* L Covelio tt«/. Risk Comparison Categorization and Ranking System
First-rank risk comparisons
   1. Comparisons of the same risk at wo different limes
   2. Comparisons with a standard
   3. Comparisons with different estimates of the sane risk
Second-rank risk compansoos (swund choice—tos dcnrahlc)
   4. Coeu)jaiisum of the risk of dousj md not doi&ft soocCbmtj
   5. Comparisons of alternative solutions to the same problem

Turd-rank nsk conptrisons (third chotut" even less desirable)
   7. Comparisons of avenge risk win peak risk at • particular time or location
   8. Comparisons of me risk from one source of a particular adverse effect wim the risk from aD
Fourth-rusk risk comparisons (fourth chfluf  maiijinilly serf pi a hie)
                         of tfau same tdveise effect
   9. Comparison* of risk with cost, or of ecstfrisk ratio with cost/risk nob
  10. Comparisons of risk with benefit
  11. Comparisons of occupational with environmental risks
  12. Csnpamm™ibttoitotieutbeu
  13. Comparisons with other •fpciffc ciusf I of Cbe sioe ducisfj fflncss, or injury
Fifth-fink comparisons (last choice— nreiy acceptable— we with ijBicum caution!)
  14. Comparisons of unrelated risks.    _
                risk agent


 Making Risk Comparisons
                                      Table II. Scales Used to Rate Covello a al. Statements.
                  This statement is dear, easy
                  to understand.
                  This statement wvU  help
                  townspeople  to better un-
                  derstand the risk.
                  This statement gives infor-
                  mation needed by towns-
                  people in their personal
                  decisions about the risk.
                                                            This statement's tone eor-
                                    This statement is unclear,
                                    difficult to understand.
                                    This statement will nor help
                                    townspeople to better un-
                                    derstand (he risk.
                                    This statement gives no in-
                                    formation  needed  by
                                    townspeople in their per-
                                    sonal decisions about the
This statement's tone un-
derMgphaiues the risk.
This statement is likely to
reassure the townspeople.
This statement is likely to
increase tbe townspeople's
trust in the plant manager.
This statement should def-
initely be included in tbe
plant manager's talk.
jnveyi i
a '
[BE rut
O 0 .
o. a
This statement's tone ov-
eremphasizes the risk.
This statement is likely to
scare the townspeople.
This statement is likely to
decrease the townspeople's
oust in the plant manager.
This statement should def-
initely be left out of the
plant manager's talk.
dle-to-upper income community (N-33); (C) members
of a synagogue  (AT-28); and  (D) members of • Prot-
estant church (jV=21) from middle and lower income
communities in Pittsburgh. The 95 total participants in-
cluded  a wide  range  of  ages,  socioeconomic back-
grounds, religions, and both sexes. Participants were either
paid $10 or had  a  $10 donation  made to their organi-
2.1.2. Materials

     In order to introduce the evaluation task, we  con-
verted the scenario described in the manual into a cover
story which read as follows:
   Suppose mat the manager of a chemical plant.that i
   ethyieoe aide in the small midwesten town of Evaaston has
   been asked (o give a talk to a local community meeting aboot
   risks posed by his plant..The local newspaper plans to reprint.
   the speech in its entirety and make it widely available. People
   in the town ate concerned about the possible risks posed by die
   plant, but there is no crisis situation or serious confrontational

     The plant manager has been a friend of yoon for many years.
   He is concerned about making' this spy*eh and, as an old Bicnd,
   has asked you for your candid advice about some things be is
   fBinitrrnff^ saying.

     Before starting, here is some background information: Eth*
   ytene oxide is used in almost all hospitals and other medical
   facilities as a disinfiwing agent. However, it can cause oncer.
   A risk assessment has shown that the cancer risk that the Ey-
   anston pftuii paces for citizens living in the town is about two
   additional tanrr 11 per year for every million people ejmoicd
   (there ire in fact only 3500 people in Evsnston). The plant
   manager i* looking for appropriate and acceptable ways to com-
   municate this risk to  the public and to compare h with other

     He warn to give a dear honest picture of the risks. He feels
   mat this is both bis ethical responsibility and that if he were to
   misrepresent the situation, eventually that would be discovered
   and him his credibility. He is concerned, however,  thai even
   an accurate statement cm come out sounding wrong or have
   tbe wrong impact. He abo wants to keep the talk (airly shon
   aid sbapk, whfle stiQ doing the topic justice.

     The foOowag are 14 dOcrem piece* of text mil tbe plant
   HiKft'jT* • coBsidenflg using m us talk. Some of them overlap
   a bit in content. Aanme that he will edit them so that they fit
   togctbf i well without men overlap. Foe each statement, pk*asg
   eve yonr advice on the following questions.

     This cover story appeared on the front  page of a
booklet that contained the 14 statements. There was one
statement per page. Each statement appeared  on the  left
side of its page, whfle the seven rating scales appeared
on the right.
     As indicated in Table n, each rating scale had five
points  with endpoiats labeled.  These were coded 1-5

                                                                                                       Roth ft al.
from left to right. With the exception of scale 4 (tone of
statement), a lower number indicates a more favorable
value. In the case of scale 4, both endpoints of the scale
represent unfavorable values (1 « underemphasizes the
risk; 5 =  overemphasizes the risk).
     The order of presenting the 14 statements was var-
ied across participants. Fifteen of group B received the
statements in Covello et ol.'s original  order, while the
'remaining 18 received the statements in the reverse or-
der. Two random orders of the 14 statements were also
generated. Approximately half of the participants in each
of the other three groups received the statements in each
of these orders.
     Groups A, C, and D completed the questionnaires
in a group setting at the site of their organization or class.
Group B members received brochures by mail.
2.2. Results
2.2.1. Results Across Croups

     Table m shows mean responses for each statement
on each scale for ail 95 participants. With the exception
of scale 4,  Covello et o/.'s proposal predicts that each
successive group of statements will hive higher means
than its predecessors.4 This was not found. Spearman
rajjk-ordcr correlations were computed between the mean
ratings of each of the 14 statements and the rank order
of the class to which it belongs. Table IV presents these
correlations, both across all 95 participants and for each
of the 4 groups.9 None of the seven scales was signifi-
cantly correlated with Covello et al's.  order in the di-
rection  predicted.  For all participants  combined, the
correlation with scale 7 (whether to include the statement
in the plant manager's talk) is dose to zero (r «  —0.13).
The only significant correlation (r  - 0.51, p <  0.05)
is that with scale 1 (clarity of statement). However, its
sign is opposite to that predicted by Covello et ol. Each
of the four groups produced a similar pattern of results,
described more fully below.
     Friedman two-way analyses of variance computed
on the rank sums across the 95 participants were signif-
icant for  all seven  scales (p <  0.001). This nonpara-
metric test indicates that there are reliable differences in
•On scale 4 i "3" wt» the matt bvonble vilue. Because til mean
 responses for tale 4 were lea than 3, higher ratings indicate more
 liveable responses.
'Analyses woe ajto performed on the rank sums for etch statement.
 The rank sum tot each scale was computed by determining each
 participant 'a rank ordering of the 14 statement*. The rank sums across
 the 95 participant* were highly correlated, with the mean scores ap-
 pearing hi the table (all correlations above 0.85), The results using
 this measure were fttrnriilly the tame i
                 Table HI. Mean Responses for the 14 Sentences on Each Scale (Avenge Across all 95 Participants)




•to scales 1
through 3 and .
5 through 7.
2.16 .
1 is the most favorable
emphasizes risk
response. For scale 4. 1 • undent!
Z54 •
Z44 -

• overemnhai
Should be
Z27 .
The stitcmeats are listed in decreasing ftwarability, according to Covello 0 aL '* predictions.

 Malting Risk Comparisons
                           Table IV. Spearman (Unk-Order Condition with the Govello et al. Raidting1
       Ail grovpi
                                               Garden dub.'
        MBA indents
 •All correlations it or above .46 ire sipifieut at the .05 level. Correlations u or ibove ,65 arc iignificam at the .01 level.
Aids understanding
Information needed
Qvcr/undertinphaiizea risk
iBcreaics trust
Should be included

JY- 33 .
W- 28
-.18 '
, W«21
 the ratings among the 14 statements (not just the differ-
 ences that were predicted).
      Table V presents Pearson correlations among the
 seven rating scales, computed on mean ratings over all
 95 participants. As can be seen,  these means tended to
 be positively and  significantly correlated," indicating that
 statements judged positively in one respect were also
 judged positively in others. These  results indicate that
 the weak correlations between scale ratings and the Cov-
 eilo a al. ranking cannot be be attributed to their being
 such poor measures that they cannot correlate with any-
 thing. Although all scales correlated with subjects* judg-
 ments of whether a statement should be included (scale
k7), the strongest predictors were how reassuring it seemed
Find whether it seemed likely to increase trust.
      The statements tended to be rated positively on all
 scales, with a rating of "1" given in almost 40% of all
 eases. One possible explanation is that the verbal labels
 anchoring the scales were too moderate (so that  1 con-
 notes good rather than excellent performance). The re-
 sulting "cefling effect" would reduce differences between
 statements, even though there were still statically relia-
 ble differences in acceptability (see Section 2.2.4). A
        Table V. Correlation Matrix (or the Sevca Scale*
                                          5   6   7
 1 Oarity              1.00
 2 Aids undemanding     0.28  1.00
 3 Information needed     0.22  0.88  1.00
 40wMnderenphaiaeriskO.32-0.52-0.fi6  1.00
 SReaatoring           0.56  0.66  OJS-0.091.00
 C bocaaea Boat         OJ9  0.74  0.72-0.490J21.00
 7 Should be included     0.53  0.71  0.75 -0.360.900.911.00
At ncfitiQBca, higher filings
Kale 4,-io that the negative co
                          elation* UK
               DflDiC fCSpOOSCS OR
               * consistent with ihc
                                   second possibility is that most statements were actually
                                   pretty good, even though some were intended to rep-
                                   resent seriously flawed  risk comparisons (see Section
                                   2.2.2. Breakdown by Group

                                        The  results are similar when the four  groups are
                                   considered separately. For three groups, there was no
                                   significant correlation between mean scale ratings and
                                   the Covello et al, ordering. For group B, there was  a
                                   negative correlation (-0.60; P < 0.05) between Cov-
                                   ello et o/.'s ranking and subjects' clarity ratings.
                                        Everyconelation between mean scale ratings of the
                                   different groups was positive, indicating a consistent de-
                                   gree of agreement. Correlations ranged between 0.23
                                   and 0.88 with a mean, using Fisher's Z-transformation,
                                   of 0.63.-
2.2.3. Effects of Order of Presentation

     Mean ratings were computed separately for each of
the four orders of presentation. Three of the four groups
wen highly similar to one another and to the overall
averages. These were the two groups receiving random
orders and the group rating the 14 statements in the order
predicted to show decreasing acceptability. These means
were all unrelated to Covello a al.'t prediction order.
The ratings of the  IS participants who received  state-
meats in Covello et o/.'i original order  were signifi-
cantry correlated (P < O.OS) in three  cues. Two were
in the predicted direction, scales 4 and 6 (—0.57 and
0.52, respectively); whfle one, scale 5 (-0.52) was hi
the opposite direction. Overall, the weak and inconsis-
tent pattern with this small group does not shake  the
general conclusion tb*T order of presentation did not af-
fect subjects' ratings.

                                                                                                     Roth et al.
 2.2.4. An Ordered Categorical Response Model
      AD ordered categorical response model, specifically
 a three-level ordered probit model, was used to clarify
 the differences in ratings among the 14 statements."*1017
 The model included the 14 statements, 7 scales, 4 orders
 of presentation,  and  4 groups as predictor variables and
 the ratings as the dependent variable. Ratings were re-
 coded into three categories, where 0 was "best" (rating
 "3" on scale 4; "1" and "2" on other scales), 1 was
 intermediate {"2" and "4" on scale 4, "3" on others),
 and 2 was "worst" ("1" and "5" on scale 4; "4" and
 "5" on  others).* The  model  was estimated in UM-
 DEP,(11) using maximum likelihood estimation. The base
 case  (represented by  the intercept) was item 14, scale 7,
 order 1,  and group  4  (D). This analysis characterizes
 predictors by beta coefficients that indicate changes in
 the underlying dependent variable, all else being equal.
 According to Covello et aL hypothesis, the beta coef-
 ficients for statements  1-13  should all be negative be-
 cause each is contrasted with statement 14, which was
 predicted to be  the  worst. The coefficients should be
 increasingly negative as the statements become more at-
 tractive and  statement number decreases. The beta coef-
 ficients for the 14 statements and their 95% confidence
 bands are presented  in Fig. 1. They  show'reliable dif-
 ferences in ratings among the 14 statements that are not
 captured by the Covello et al. ranking system, even when
 effects  of scale, order  of presentation, and group are
 statistically controlled.  The  beta coefficients typically
 had the wrong sip (positive). There  was no consistent
 trend over the five ranks.
     The analysis yielded significant coefficients for scale
 and group, but not for order of presentation. The  lack
 of an order effect with this more sophisticated analysis
 strengthens our inclination to discount the weak differ-
 ences reported in Section 2.2.3. The overall  fit of the
 model is moderately good. The x3 statistic from the log-
 likelihood ratio test is highly significant (727J, 24 df,
p < 0.001) and the model correctly predicts 55% of the
*Aa entered probit oodel assumes that me atoned ratings m discrete
 ad hive onfatl properties (i.e., BO intervii relation between nting
 poms ii assumed}, but thai the anderryrag (uutembie) dependent
 variable (Le., statement acceptability) it eoottnuoot cod normally
 distributed, conditional m the predictive variable*.
The origin*] five-point tilings for ill scales, except 4, were also fit
 with an analogous mode! is was an alternative J-poinl set of collapsed
 ratings (0- 1; 1 • 2J.4; 2 - 5 far all sales except 4. which was
 eollapsed u above). Similar result* were obtained and are available
 upon request.
 Flf. t. Estimated beta coefficients for the statement dummies from
 the ordered probit regression model, with 95% confidence intervals
 marked (based on the coefficient'} estimated standard deviation).
 Statemeni 14 is the base case (intercept).

     Our subjects' ratings reliably distinguished among
the statements, but not in the way predicted by Covelio
a al. This section discusses why Covello ei al's predic-
tions might have fared so'poorly and offers some alter-
native perspectives on risk comparison statements.

3.1. Risk: Comparison* Deviating From Predictions

     One place to look for insight is at those statements
whose ratings deviated the most from the CoveUo « al.
predictions. As can be seen in Table ffl, three statements
at the top of Covello et aL's list were near the bottom
of our subjects' ratings, while three of  the four worst
statements according to CoveUo a al, were rated among
the best  here.
3.1.1. Comparisons of Risks Across Domains Fared
Better Than Expected

     According to Covello et at. and others,™ risk com-
parisons are particularly problematic when they involve
risks with very different features. Ac • result, the ex-
amples that Covello a al. identify as worst involve risks
from different domains. Their statement 13 (representing
cumpaiiaoas mat invoke other specific causes of the same
consequence) compares the risk  of cancer from  the
chemical  ethyiene oxide to the risk of cancer from x-
rays. Their least favored statement (14) compares eth-
yiene oxide with other hazards whose consequences did

 Making Risk Comparisons
 not  include cancer (e.g.,!ightning).  Nonetheless, both
 statements were in the top half of the set for six of the
 seven scales. Indeed, they were the highest ranked state-
 ments on scale 2, how much a statement would "help
 townspeople to better understand the risk."
     Covello et al.'s critique of cross-risk comparisons
 applies most strongly to cases where they are advanced
 with a rhetorical purpose—of the form  "if you  accept
 Risk A, then you ought to accept (equivalent) Risk B."
 Such comparisons have,  however, no logical force un-
 less the two risks are equivalent oa all their risk features
 (sot to mention their associated benefits and control op-
 tions). A more  modest use of risk  comparisons is to
 convey a feeling for the magnitude of a risk, with no
 claim of acceptability. Such magnitude comparisons might
 focus on either the probability of negative consequences
 (e.g., as likely as being struck by lightning during an
 equivalent exposure period) or on their  intensity (e.g.,
 as painful as a root canal without anesthesia). Given their
 more limited ambitions, magnitude comparisons should
 be easier to make appropriately than  acceptability com-
 •   Conceivably, Covello a o/.'s own sensitivity to these
 issues kept them from creating  truly bad risk compari-
 sons, particularly ones containing indefensible accepta-
 bility arguments. As a result, our subjects were able to
      on the magnitude comparisons in the statements.
 These were, in turn, executed relatively well. If that is
 the case, then, in effect, CorveUo « al. foiled their own
 prediction when they created the illustrative statements.
3.L2.  Comparison of Occupational with Environmental
Risks Fared Better Than Expected

     A second  unexpected success was statement 11,
which was intended to exemplify comparisons between
occupational risks and environmental risks. Rather than
emerging near the bottom of the ratings, statement 11
appeared in the top half of all seven  scales. It was ranked
best on scale 3 ("gives information needed by the towns-
people in their personal decisions about the risk") and
was one of the  top 3 statements on scale  2 ("will help
townspeople to better understand the risk") Covello et
at.  do not explain why they expected such comparisons
to be received particularly poorly.  One possible reason
is that the assumption of occupational risks often implies
the acceptance of risk—benefit tradeoffs that seem quite
inappropriate outside of working life.
     However, although Covello et aft statement 11 does
refer to occupational and environmental  nsks, it does
not invite risk-benefit comparisons. Rather, its main thurst
 is that the risk to employees is very small, implying that
 the risk to the community will be even smaller. Again,
 the example may have fared unexpectedly well because
 it lacked the particular feature of its category that people
 find objectionable.
3.1.3. Comparison with a Standard and Comparisons
with Different Estimates of the Same Risk Fared Worse
Than Ejected

     Covello et at. stressed the importance of being hon-
est and forthright in providing risk information. Ele-
ments of such frankness include indicating uncertainties
or disagreements regarding the size of the risk, discuss-
ing worst-case estimates as well as best-guess estimates,
and noting how a risk compares to various proposed
standards, of acceptability.
     Statements 2 and 3 were intended to exemplify this
principle. Statement 2 compares  the focal risk to five
different emission standards, while statement 3 provides
six alternative estimates of the size of the risk, based on
different data, different assumptions, and different orig-
inating sources.  Both statements  should have been  at-
tractive.  However, each was ranked in the bottom half
of the set cm six of the seven scales. They were among
the wont ttoec items on scale 1, measuring how "dear,
easy to understand" a statement  was. This last result
suggests that these statements may have been ranked so
poorly because of the quantitative and probabilistic  in-
formation that they contained. The price paid for such
candor may have been confusing recipients. Statement
3 may have been particularly difficult because it included
•mall probabilities presented in decimal  form (e.g., 0.007
cancers per 3500 persons). The Covello et al. manual
itself explicitly warns against this format. Statement 8,
which was designed to reflect a more effective way of
communicating small probabu*itks,  had some of the worst
ratings on the darity scale. Apparently, we still have
much to lean about presenting such information.
    A second possible source of confusion in these
statements was the  need to integrate the multiple per-
spectives mat they presented. For example, what are
recipients to nuke of a risk that  meets one of seven!
standards, especially when they know little about the
organization that set each standard  or the purpose for
which it was set? Similarly, how ue they to recodle
competing scientific estimates of a particular risk with-
out understanding the underlying science (and scientists)
producing those  estimates? Offering multiple perspec-
tives may be a meaningless gesture unless recipients can

put them into context. Clearly, more research is needed
here as well.
3.1.4. Comparisons of Risk of Doing and Not Doing
Something Fond Wane Than Expected

     Statement 4, which was intended to illustrate com-
paring the risks of doing and not doing something, re-
ceived unexpectedly poor evaluations. It  ranked in the
bottom half of the set on six of the seven scales, faring
particularly poorly on scales 1 (clarity), 5 (reassuring),
and 6 (increases trust). It shared the bottom in the or-
dered probit analysis (Fig. 1). Here, too, presenting small
probabilities in decimal  form may have been problem-
atic. In addition, statement 4 notes that the risk could
be  reduced (by a  small amount)  by  purchasing new
equipment, but without indicating whether the plant in-
tends to do so. Silence  on  that issue may have raised
suspicions and reduced ratings related to trust.
3.2. Explanations for Failure of Predictions

     Reviewing our results in  the light of these argu-
ments suggests three reasons why Covello et a/.'s pre-
dictions may have failed.
3.2.1. Flaws m Measurement
3.2.2. Flaws in the Examples

     A second  possible source of failure is that the  14
statements did not capture the essence of the categories
that they were meant to represent. 'Section 3.1. raises
some such possibilities (e.g., avoiding the risk accept-
ability arguments that can make some categories offen-
sive, burdening relatively sound comparisons with
unfamiliar decimal probabilities). The fact that recog-
nized experts of this field might encounter such problems
suggests the limits to our understanding of risk compar-
3.2.3. Flaws in the Underlying Theory

     A third possibility is that the theory underlying the
ranking system is flawed. It is always difficult to falsify
a theory when  there is uncertainty about how it should
be implemented and evaluated.  Nonetheless, it should
be troubling to find failures with statements produced by
the theory's creators and evaluation scales adapted from
their stated objectives.
     In  Covello et a/.'s  theory,  there are two obvious
places to work on: its classification scheme and the pre-
dicted rankings of its categories. Covello et a/.'s clas-
sification scheme sons risk comparisons primarily
according to what risks  are being compared, and only
secondarily according to the purpose of the comparison
or the specific  information that it contains. Elaborating
these features may be a way to improve our understand-
ing of risk comparisons.
     The first possibility is that Covello et a/.'s theory
is correct, but our rating scales failed to measure what
they intended by "acceptability." As mentioned, we used
a variety of rating scales in an attempt to capture the
diverse elements of the complex notion of "acceptabil-
ity" advanced by Covello et al. It it, of course, possible
mat none of our rating  scales was related to the lay
notion of "acceptability." However, the fact that so di-
verse a set of scales failed to correlate with Covello et
aTs predicted ranking indicates the need  to clarify the
goals of risk comparisons as well as to study how to
reach them.*                                :

'Any other future of oar neuareaeai procedure might also be ailed
imo question. For example, in their thoughtful ropoaie to (fan trade,
Stevic « «/."* wonder ibout whit would hive happened hid w* ned
toother cower story. Pioyiess here itc^oiits ucouittiiig fox both those
pitignu ihu oid e&tetifc in ptcviuus imUffit n well  u for (BUB (bit
did not.
3 J. Toward a Systematic Classification of Risk

     One significant contribution of the Covello et al.
proposal is describing the variety of features of a risk
mat comparison statements can highlight. Indeed, each
category in their system deals with a different aspect of
risk. For example, statement 1 describes trends over time,
while leaving the communication of absolute and relative
magnitude to other statements. It seems unlikely that any
criterion of acceptability could apply to messages having
such a variety of purposes. Each is legitimate for some
purposes and  flawed for others, with its acceptability
depending heavily on the quality of its implementation.
     One wty to conceptualize the potential purposes of
risk comparisons is according to the roles that they may
play in helping people to make decisions about risks.
From a decision theory perspective, a decision involves

Making Risk Comparisons
  choice among options, each of which can be charac-
terized by a vector of attributes, representing its possible
consequences. With risky decisions, at least some of
those attributes involve uncertain negative conse-
quences. When  considering decision options (risky or
otherwise), one needs to go through three stages: iden-
tifying the set of relevant attributes (i.e., the ones that
might mancr when one makes a choice), characterizing
each option in terms of each attribute, and determining
the relative importance of each attribute (in this set of
     Risk comparisons have a legitimate role to play in
supporting each of these stages. That is, they can help
people to determine:

     1.  what attributes merit consideration;
     2.  how each option rates on each relevant attribute;
     3.  how those attributes should be weighted.
3.3.1. Evoking Attributes of a Risk

     Risk perception research has found that people are
capable of rating risks on a large set of attributes (e.g.,
voluntariness, equity, dread), which are relevant to their
   gmcnts of risk acceptability."*14' The fact that these
   ibutes are  recognized when they  are presented ex-
plicitly carries, however, no assurance that will be re-
called spontaneously when a risk is mentioned. Indeed,
the great number of possible attributes means that it would
be hard to bear all in mind at once. A risk comparison
might be able to help people by evoking decision-rele-
vant attributes that they might otherwise neglect. Doing
so in an unbiased fashion will pose a challenge to the
design of communications. Considerations that are out
of sight tend to be out of mind.'"-16'  Conversely, those
comparisons that  are made may powerfully shape the
attributes that people do consider (e.g., "This is the next
dioxin"  or "They tell us this is safe, but that's what
they said about cigarettes and Agent Orange" or "They
are just like tobacco company scientists").
3.3.2. Determining the Values on Risk Attributes

     Once the attributes relevant to a decision have been
option rates on each attribute. Conveying information
about the magnitude of consequences is one clear pur-
pose of risk communications. As mentioned, risk com-
parisons might be a useful tool for doing so, by providing
a familiar point  of comparison for an .unfamiliar haz-
ard—as long as claims of risk acceptability can be avoided.

3.3.3.  Crystallizing Preferences               :

    A final role for risk communications is helping peo-
ple examine and  crystallize their own preferences. Sim-
plistic models of decision-making assume a high degree
of articulation in people's preferences, namely, they will
know how to make all relevant tradeoffs, judging  the
relative importance of different outcomes. However, with
options involving the sort of esoteric consequences in-
volved with many risky decisions, people may welcome
noncoercive suggestions of alternative perspectives.'171
Properly qualified risk comparisons might fulfill that role.

3.4. Reflections  on Category Definition

    The analysis above suggests that the details on con-
tent may be more important than the form of a risk com-
parison in determining its acceptability. This may explain
some of  the lack of predictive  power of the Covello el
al. classification scheme. In some cases, the categories
in Covello et al'i taxonomy are sufficiently broad to
include statements with quite varied character.  Con-
versely,  statements that communicate very similar .in-.
formation 9y different  means are sometimes classified
separately. For example, statement.il uses the experi-
ence of plant employees as an upperbound estimate of
the risk to the townspeople. As such, this statement might
arguably belong in category 6 with (other) comparisons
that use the risk level experienced by one group  as an
input to estimating the risk to another.
    Category 4 ("comparison of the risk of doing some-
thing versus not doing if) provides another example of
a category that includes comparisons with varied con-
tent. For example, it includes  both actions intended to
increase risk and actions intended to reduce risks, which
may invoke different attitudes. Moreover,  all such com-
parisons invoke risk—benefit tradeoffs, insofar as as other
consequences accompany these actions. As a result, cat-
egory 4 overlaps category 9. The fact that these tradeoffs
are left implicit  in statement 4 may account for  some
reasons why it was judged more poorly than statement
9, where the tradeoffs are explicit.

     Covello et al. have enumerated and classified a va-
riety of risk comparisons. They were not, however, .able

                                                                                                Roth a aL
 to predict the acceptability of statements generated to
 represent those categories, at least as measured by our
 subjects" responses. This failure seems to reflect a com-
 bination of (1) difficulty in  translating the  theory into
 concrete communications, (2) confounding the different
 possible purposes of risk comparisons within individual
 messages, and (3) the absence of adequate research on
 how te represent different kinds of information credibly.
 As a result, we need more  and better theoretical and
 empirical research to build on Covello a al.'s challeng-
 ing beginning.

     The following is the text of the 14 specific risk
 comparison statements, developed by Covello et- al.
 (1988), which were evaluated in this research.

 Statement 1

     "Health risks from emissions of etfaylene oxide at
 our plant are 40% less than a year ago, when we installed
 exhaust scrubbers.  With more equipment coming in, we
 expect to reduce the risk another 40% by the end of the
 next year."
     "Despite the extremely low health risks to the com-
 munity from emissions of ethylene oxide at our plant,
 we are still looking for ways to lower these levels fur-
 ther. These are some of the plans we have under way to
 accomplish this: (provide specifics). As we implement
 these steps, we will keep you and the community in-
 formed of our progress. We will also continue to monitor
 our workers and keep track of health statistics within the
 community to ensure that the risks posed by our plant
 to our workers and to the community remain in the future
 as low as, if not lower than, they are today. Since some
 of you may have further questions about these and other
 matters concerning our plant operations, as plant man-
 ager, 1 am providing my work aad home phone numbers
 so you can  call me. I will do my best to supply you with
 answers to  your questions as quickly as possible."

 Statement  2

    "Emissions of ethylene oxide from our plant are
half the levels permitted by the U.S. Environmental Pro-
tection Agency and by our state's Department of Envi-
ronmental Protection.
    "Emissions of ethylene oxide from our plant are
 five times lower than the U.S. Environmental Protection
 Agency's safety standard."
     "Plant emissions of ethylene oxide are five times
 below what was permitted under the old EPA standard,
 and two times below the level established by the new,
 stricter EPA standard.
Statement 3

     "Laboratory studies on rats and mice suggest that
current exposure to ethylene oxide may cause seven can-
cers in 1000 generations of  residents in mis city. This
estimate is the maximum that would occur under worst-
case conditions. Actual health effects from exposure to
ethylene oxide are likely to be lower."
     "Let me try to put this  number into the context of
other numbers. We've said that our worst case prediction
is seven thousandths of one extra cancer within the next
70 years from our plant's emissions of ethylene oxide.
Now,  no one ever gets seven thousandths of a cancer.
A better way to see the effect  is that  if 130 different
communities the same size as Evanston had a plant just
like this one, 129 of those towns would see no effect on
their cancer rate. One of the 130 Evaostons might have
a single extra cancer."
    •"Our best estimate of the risk is 0.001  cancers per
3500 persons using what we believe are realistic as-
sumptions. This estimate is based on work done by our
own scientists and by researchers at Evanston Univer-
sity. However, you should be aware that the state De-
partment of Environmental Protection (DEP) has calculated
a worst-case risk estimate-of 0.007 cancers per 3500
persons. DEP made the assumption  that all individuals
Irving  in Evamton would be expressed to emissions of
ethylene oxide 24 hours a day for 70 years. This formula
gave DEP  a human-lifetime dose. DEP then took  the
best  available laboratory information for ethylene ox-
ide—data obtained from studies oa the laboratory mice
most likely to develop cancer in response to ethylene
oxide—and calculated first the lowest dose that caused
adverse health effects in mice and then the equivalent
dose in humans. On the basis, of these and other pieces
of information, DEP concluded  that  the mjTimnTn can-
cer risk to people in  the community is 0.007 cancers per
3500 persons over 70 years."
    "Our worst-case estimate of the risk is seven thou-
sandths of a cancer  per 3500 persons over the next 70
years.  How sure are we that  me risk is really mis low?
The bad news is mat we're not  as sure as we'd like to
be. Risk assmrnffrt is a pretty  new science, based oa
models and assumptions rather dun hard data. The good

Making Risk Comparisons
 lews is  that we're almost certain the  risk is  actually
smaller than our estimate—we've instructed our scien-
tists to make every assumption on the cautious side, to
provide aa extra margin of safety. And here's a piece of
hard information. We've been manufacturing ethylene
oxide in Evanston for 35 years now. We have contin-
ually monitored our employees for signs of adverse health
effects associated with exposure to ethylene oxide. In al!
that time, as far as we know, not a single worker or
retiree has had the sort of cancer normally associated
with ethylene oxide.  Please  keep in mind that  these
workers  are exposed  to consistently higher levels of
emissions than the surrounding population is. Therefore,
on the basis of our workers' experience so far, the risk
is zero. There are also people who think our risk estimate
is too low. The Evanston  chapter of the Sierra Quo
estimates seven hundedths of a cancer per 3500 persons
over the  next 70 years. That's 10 times  higher than  our
estimate—but even if they're right, it's still an extremely
small potential increase in the cancer rate. And we hav-
en't found anyone with a higher estimate than theirs."
Statement 4

     "If we buy and install the newest and most ad-
vanced emission-control equipment available, the worst-
     situation  is that the maximum total risk will be
      additional cancers per 3500 persons,  a very low
number. If we don't buy new equipment and  keep op-
erating the plant with our current pollution-control sys-
tem, the worst-case situation is that the maximum total
risk will be 0.007 additional cancers per 2500 persons—
also a very low number. Please keep in mind that both
of these risk estimates are worst-case estimates."
Statement 5

    "The maximum health risk from our plant's emis-
sions of ethylene oxide is 0.007 additional cancers per
3500 persons. We could switch to producing the only
known chemical substitute for ethylene oxide. However,
the maximum health risk of emissions of that chemical
is 50 times higher."
Statement 7

     "The risk posed by emissions of ethyiene oxide is
extremely low, no matter where  you  live or work  in
Evanston. However, the risk posed by emissions of eth-
ylene oxide for people Irving two miles from the plant
is 90% less, than for people living in the nearest home;
and the risk for people living in the nearest home is 90%
less than for people working within the plant gates. And
our workers haven't had a single case of the  type  of
cancer normally thought to be linked to ethylene oxide."

Statement 8

     "Let me see whether these numbers will  help.
Roughly a quarter of all of us get cancer—a disease
caused by smoking, diet, heredity, radon in the soil,
pollution, and many other factors. Out of 3500 people,
medical data show that one-quarter—or about 875—are
going to get cancer sometime  in  a lifetime. So here's
the predicted effect of ethyiene oxide emissions from
our plant on the overall cancer rate. In 129 of  130 hy-
pothetical Evanstons, no effect—that is, no expected in-
crease in cancer rates at all. In the 130th, cancer rates
would rise from 875-876. Although this is only a tiny
increased risk, it is still an increase. If we can find a
way to make it even smaller, we should and we will.
The most important thing is for all of us in Evanston to'
work together to find ways to bring down the total cancer
rate, that unfortunate 875 out of  3500. But we at our
plant have a special responsibility to be safe neighbors.
Much higher risks due to other factors are no reason  to
ignore a small risk  in our facility. Here's what we're
doing to make sure we keep the risk from our  plant  as
low as it can possibly get: (provide details).*'

Statement 9

     "During the next year, our plant  will spend more
than $2 minion to reduce oar  already small emissions
even further. This new investment will hurt us econom-
ically but wfll reduce the risk of cancer in the community
by more than 25% when fully operational.**
Statement 6

    "We have installed in our plant the most advanced
emission control system now operating in the country.
Compared with those of older plants, such as the one in
Middletown, our emissions are 10 times less."
Statement 10

    "If we stopped producing ethylene oxide today,
many more people here and throughout the United States
might die  than could possibly be affected by emissions
from our Evanston plant. Ethylene oxide is the best ster-

ilizing agent used by hospitals today. No equivalent sub-
stitute for cthylenc oxide is available. Continued
production of this production will contribute to saving
many lives and will ensure that the surgical instruments
that doctors and hospitals use are free from infectious
•gents."                                 ;
Statement 11

     "One way to look at the data is to compare the
risks of emissions of ethylene oxide to plant neighbors
with the risks to plant employees. We have been oper-
ating this  plant for 35 years, with ao average employ-
ment of 400 people. We therefore have about 10,000
person-years of worker exposure to ethylene oxide at this
plant. Health monitoring at our plant indicates that the
average workplace concentration of ethylene oxide is 0.5
ppm, a dose 200 times higher than that in  the commu-
nity. The  primary health concern about ethylene oxide
is its potential for causing certain types of brain cancer.
We  have  not had a single case of brain cancer  in our
work force.  Moreover, the overall incidence of cancer
in our  employees is lower than that of the U.S. popu-
lation as a whole. Nor has Evanston's health department
documented any brain cancers among our workers. On
the basis of this information, I.believe that the  health
risk  posed by the plant to the community is insignifi-
Statement 12

    "I believe that our ethylene oxide emissions do not
pose a significant health risk to the community. I also
believe that our emissions pose a much less serious prob-
lem than our hazardous waste problem, which is dairy
becoming more serious because the repositories in our
state are filled and none are being built."
Statement 13
    "One way to look at the cancer risk from «
of ethylene oxide in our community is to compare the
risk with the cancer risk from the x-rays you get during
a health checkup. Oae  chest x-ray per year presents a
risk of developing cancer that is twice that of developing
cancer from our plant's emissions of ethylene oxide."
Statement 14

     "Another way to get some perspective on the risk
of ethylene oxide emissions is by comparing it to some
of the risks that we all face in our daily lives, such as
the risk of being killed by lightning or the risk of beng
killed in an auto accident. My purpose in making such
a comparison is only to put the size of the risk in context.
I recognize that such comparisons are like comparing
apples and oranges^ Still, I  think the comparison can
help us all understand and gain some perspective on the
size of the risk we are  talking  about. For example, the
risk of death by salmonella food poisoning from poultry
bought at the local supermarket is at least five times
greater than the risk of cancer from the highest exposure
to ethylene oxide in this community."
     "You may be wondering, 'But what does that mean
to me as a resident of this community? What's the risk
to me and my family?' First let me tell you that I am
convinced that there  is no threat to the health or safety
of any member of our community at these extremely low
exposure level. However, I recognize that the data still
may be troubling. So it would probably be  helpful to put
these levels of risk from exposure to ethylene oxide into
the context of other  risks that we're  all exposed to in
our daily lives. For  example,  the risk to the average
Ameijcan of  death from lightning is at least 140 times
.greater than  the risk of  cancer in Evanston from  the
highest exposure to etbylene oxide. Hurricanes and tor-
nadoes also pose a risk about 140 times greater. Insect
bites pose a risk about 70 times greater. The additional
0.007 cancer risk is about the same as the additional
cancer risk you would incur spending four hours in Den-
ver rather than at sea level because of Denver's high
altitude and higher radiation level."

     We thank C Atman, C Cortes, G. Hester, R. Lie,
L Nair, wi4 P. Steranchak for their E$ff***?ii(?B in this
work. We received helpful comments on a previous draft
of the manuscript from G. Hester, J. Mcrz, D. Resendiz,
P. Sandman, and P. Slavic. The work was supported by
National Science Foundation grant SES-871564. The
views expressed as those of the authors.
 1. V. T. CbvtilQ. P. M. Sandman, tod P. Sow, Rut Ceamaou-

Making Risk Comparisons
    Managers (Washington. D.C, Chemical Manufacturers Associ-
    ation. 1988).
 2. B. Cohen tnd 1. S. Lee,. "A Catalog of Risks," Health Physics
    X, 707-722 (1979).
 3. R. Wilson, "Analyzing the Risks of Everyday life," Technology
    Xcvtcw 11 «M6 (1979).
 4. Environmental Protection Agency, A Ciattn't Guide 10 Ration:
    What It it aid What to Do About It, 13 pp.  (Washington, O.C
    1986). 13 pp.
 S. B. Fachboff, P. Slavic, and S. Uduemtein, •'Weighing the Risks,"
    Environment 2117-20, 32-38, (1979).
 6. B. Fischhoff, S.  Lichtemeia, f. Slovic. S.L Derby and R.L.
    Kceney, Acceptable Risk (New York, Cambridge University Press.
 7. Nations)  Research Council,  Improving Art Communication
    (Washington, D.C, The Council. 1989).
 8. B. Ftschhoff. S. Watson, and C Hope, "Defining Risk," Policy
    Sciences 17.123-139 (1984).
 9. A. Agresti, "Tutorial on Modeling Ordered Categorical Response
    Data," Psychological Bulletin iOS 290-301 (1989).
10. R. D. McKervey. and W. Zaviona, "A Statistical Model for the
    Analysis of Ordinal Level Dependent Variables," Journal of
    Mathematical Sociology 4 103-120.
11. Greene, W. H. UMDEF (Self-published statistical software pack-
    age and manual, 1982).
12. P.  Slovic,  N. N. Kraus, and V. T. Covelto, "Comment: What
    Should We Know About Making Risk Comparisons," Risk Anafy-
    til in press (1990).
13. B. Fischhoff. P. Slovic, S. Lichtensiein, S. Read, and B. Combs,
    "How Safe b Safe Enough? A Psychometric Study of Attitudes
 •   Towards Technological Risks and Benefits." Polity Sciences 8,
    127-152 (1978).
14. p.  Slovic, "Perception of Risk," Science 336,280-2S5 (1987).
IS. B. Ftschboff, ?. Slavic, and S. Uchtenstein. "Fault Trees: Sen-
    sitivity of Assessed  Failure Probabilities to Problem Representa-
    tion," Journal of Eiperimental Psychology: Human Perception'
    tnd PaformoMCt 4, 330-344 (1978).
16. A. Tvenky, and D. Kataemaa, "Availability: A Heuristic for
    Judging Frequency and Probabfliry," Cqgiwt* Psychology S: 207-
    232 (1973).
17. B. Fiscaboff, P. Slavic, and S- Uchtenstein. in T. Wallstea (ed.).
    Cognitive Pnceaet at Choiet aid Decision Behavior (Hillsdale.
    New Jersey. Erlbaura. I960).


RukAnafyns, VoL 10. No. 3, 1990
What Should We  Know About Making  Risk
                                         v       ^,   •.        v.
Paul Slovic,2 Nancy Kraus,3 and Vincent T. Covello3
     The study by Roth a al. w provides a valuable
lesson for risk communicators—test your messages. The
factors that determine how a person interprets a risk
communication are subtle and not well understood. As
a result, those who draft and disseminate risk messages
cannot accurately predict how they will be interpreted
and what influence they will have.
     The results obtained by Roth a al.  are surprising
in many ways. Particularly surprising is the finding that
the comparisons of unrelated risks were rated relatively
favorably. Although such comparisons have been strongly
recommended for more  than 25 years as ways to put
risks in perspective, <2A*> they  have been criticized for
ignoring many of the quantitative and qualitative factors
that determine the perception and acceptance of risk.'*'
A harsh editorial in Nature, following Lord Rothschild's
advocacy of such comparisons, <*> described them as
"the kindergarten of risk." The data obtained by  Roth
ft al. suggest, that these criticisms may have been mis-
placed, and that comparisons among unrelated risks, if
framed carefully, may indeed provide valuable insights.
     Before breathing new life into comparisons of un-
related risks, we would like to offer several reasons for
restraint and further study. The first pertains to the fact
mat the study by Rom et al. employed only one scenario.
In this scenario, respondents were asked to evaluate the
comparison statements from the perspective of advising
a plant manager who is about to communicate to a con-
cerned community in a noncrisis, nonconfrontational at-
mosphere.  Many plant managers must communicate in
just such a setting. However, we believe that it is im-
portant to replicate this study within  diverse contexts,
including a setting where the community it angry or
distrustful as well as a benign setting in which trust,

> Received March 5.1990.
1 Dedaon Retearcb, 1201 Oik Street. Eugene, Oitfon 97401.
* Center for Risk Communication. School of Public Health, Cohnnbi*
 Univenity. New York, New Yak 10032.
 mutual respect, and meaningful public involvement pre-
 vail. We would expect comparisons of unrelated risks to
 be relatively less satisfactory as  the context becomes
 increasingly hostile.  Second, other comparison  state-'
 merits should be evaluated in addition to those drafted
 by Covello et o/.m. Third, we would like to emphasize
 a point made by Roth a al., and  to provide some sup-.
 porting evidence. Roth  a al. suggest that the specific
 comparison of unrelated risks drafted by Covello et al.
 may have done well  because it did not argue that the
 risk of cancer was acceptable because it was equal to or
 smaller than other risks that are  commonly accepted.
 Instead, this message stated that the "...'purpose in mak-
 ing such a comparison is only to put the risk in context" '•
 and "...tagain some perspective on the size of the  risk."
     We believe  this to  be a critical point. Many com-
 parisons of unrelated 'risks do not include this qualifi-
 cation. Instead of adopting this modest objective (i.e.,
 providing  perspective),  comparisons of unrelated risks
 are frequently advanced as a means for setting priorities
 and determining which risks are acceptable.™ More spe-
 cifically, they are advocated as a means for determining
 which risks to ignore, which risks to be concerned about,
 and how much risk reduction to seek.(3-*-*-*>
     We believe that these arguments are flawed and that
 risk acceptability depends on a wider range of factors
 than the probabilities or fxrxrrtrrl fatality or morbidity
 estimates that art typically compared. Comparisons that.
 stress acceptability of risk are, therefore, vulnerable to
 criticism. To support this daim, we would like to offer
 some additional empirical data. We have conducted an
       nent in which subjects played the role of jurors
 in a simulated trial in which a company that supplied
 tsbfSTM insulation Tj|a*g">t* was charged with exposing
 the students and staff of • school to unreasonable risk
' the use of this product in the school building did not
 pose a health hazard to the  students and staff of die

                                                                                                 Stovic et at.
    The subjects is this study were 117 persons who
answered an ad in a community newspaper. They were
assigned to one of three groups, each of which received
different information about the risks from asbestos and
other hazards. All subjects were given the same back-
ground briefing about the nature of asbestos and its health
hazards. They were also given background information
about the  trial. Finally, all subjects were  told that an
authoritative source had determined that the average con-
centration of asbestos in the air at the school was .001
fibers per cubic centimeter and that students attending
the school for three yean faced  an increased lifetime
fatality risk of 0.23 per million.
     The three information conditions differed as fol-
lows:   .
     Group I received no  additional information. They
were asked to  answer the following questions about risk
and guilt:

     1.  In your opinion, how high is the risk of exposure
        to the  asbestos concentrations found at Jefferson
        Junior High School?
        very low        moderate         very high
           risk             risk               risk
     2.  If you were on the jury in this case, would you
        find (the company] guilty or not guilty of ex-
        posing the students and staff of Jefferson Junior
        High School to unreasonable risk of disease re-
        sulting from exposure to asbestos  fibers intro-
        duced into the air  by their products?
        [     ] guilty       I    ] not guilty

     Croup tt received the same background information
followed by Exhibit A (shown in Table I), comparing
the asbestos risk with risks from smoking, diet soft drinks,
chest x-rays, peanut  butter, and  background  radiation
from living in  a brick house. Accompanying Exhibit A
was a statement by a (fictitious) expert witness. Dr. A.
Davis, called on behalf of the defendant  to explain and
interpret the risk comparisons in the table. Dr. Davis
concluded his  explanation with the following opinion:
   So now. if we look at OK riak aaaociiied with berni expoeed
   to aabems fiben white attending Jeflenoa Junior High School
   for three yean, ii'i teat than one — 0.23 deaths per million to
   be pKCtK. Thai'* a voy email fiioJoo of (be risk estimated
   for drinking diet aodaa at wen tot eating peamt buna snd-
   wtchea. So, WWB iwUgh CXBOBHTB to aaoettoa at very Ugh
   laveia ha ben abownto caaae diaeeae, I'd haw to my, baaed
   on my prefeaaionai experience sod aa a comrned rtiam, thai .
   I would have no concern if anyone — including pcraona from
   ny own family •^ wew to attend Jeftnon Junior High School

After examining Exhibit A and reading Dr. Davis' state-
 ment, subjects answered the two questions about risk
 and guilt.
     Subjects in group I were also shown the compari-
 sons in Exhibit A after making their judgments and they
 were asked to answer the two questions a second time.
     Group HI was given the same information as group
 n, including the table of risk comparisons and the state-
 mem by Dr.  Davis. In addition, subjects in this group
 were given a statement by a (fictitious) expert witness
 for the plaintiff. Dr. F. Stewart, criticizing the compar-
 isons shown in Exhibit A. Dr. Stewart's testimony, which
 argues that Exhibit A has no logical  implications re-
 garding the acceptability of the asbestos in the school,
 is presented in Table H.
     Table HI presents the mean risk rating and the per-
 centage of guilty judgments for the three  information
 conditions. Data from group I show that the 0.23 lifetime
 risk estimate, presented alone, evoked a moderately high
 rating of risk  and a judgment of guilty by more than half
 of the subjects. Seventy percent of these same individ-
 uals, shown the  comparisons in Table I, subsequently
 lowered their judgments of risk; no  one gave an in-
 creased risk  evaluation. Judgments of guilt were less
 influenced by the comparisons in Exhibit A.
     Croup n, which responded only after seeing the risk
 comparisons, had a significantly lower mean risk judg-
 ment* than group I (p < 0.01) and a  markedly lower
 percentage of subjects finding the company guilty {p <
 0.05). Presented without challenge. Exhibit A was clearly
 effective is reducing subjects' concerns.
     Responses from group ID, however, wen virtually
 the same as those from group I, suggesting that the ef-
 fects of the comparisons on perceived risk and judged
 guilt were fulhy offset by the critique presented in Table
     Technical analyses of the asbestos problem have
      Ttabk I. ExUbJt A: LUetfna
per Million
                                                                                        Deaths per million penona
- Smoking one pack of agvettes each day
   tor 20 yean

 Cheat soya .<>•:•...    : •  •%»•

   day (afliiadn)
 Living m a brick honaa (notation)
 Anendng JefTeraon Junto High School for
   3 yean (aabeam baaed on 0.001 fiben



Bisk Comparisons
 Table IL* Statement by Or. P. Stewart. An Expert Witness Called
 on Behalf of the Plaintiff, Jefferson Jr. High School, in Testimony
           About the Statistics Presented in Exhibit A

Dr. Stewart
  As I understand it. Exhibit A shows the risk per million penoas of
dying from the activities listed. The numbers shown on the chut ire
estimates, based on statistical analyses.
  In ray opinion, the numbers ia this cfaan are misleading, and fail to
have any logical implications for the asbestos decision under consid-
  First, the estimates in the Exhibit may not be accurate, particularly
to the case of asbestos. Toe risk value given for asbestos is based on
in average reading of .001 fibers per cubic centimeter. But. at times,
the level of asbestos fibers people in the building are exposed to may
be much higher (for example, when repair work is being done). The
average exposure given in the exhibit may not accurately represent the
risk from such higher "peak" concentrations.
  My second objection is more fundamental. The bet that one risk is
accepted does not necessarily mean that another, lower risk is accept-
  Acceptability must weigh risks against benefits. The risks from as-
bestos, no matter how small, are not acceptable if there are no com-
pensating benefits or if there are less risky alternatives that can provide
similar benefits.
  Furthermore, most of the risks presented in Exhibit A arc voluntary
activities.  Attending a school contaminated by asbestos is involuntary,
not under  the control of the children who are at risk.  The standards
for acceptability need to be much stricter for exposing children invo-
luntarily to risk.
  So, I'd  have to say, as a professional and as a parent of school-age
children, that the risks from exposure to the asbestos levels found at
Jefferson Junior High may indeed be low. They may be very low. But
1 wouldn't want to expose my kids even to a theoretical risk of asbestos
if I didn't have to.
    Table HI. Perceived Risk and Judgments of Guilt for Three
                  Information Conditions*
Group Presented
Lifetime risk
Lifetime risk plus
Mean perceived% finding company
N risk guilty
30 3.33(2.13)
27 2.48
       Exhibit A
Hi   Lifetime risk
       Exhibit A. and
       critique of Exhibit A 60  3.53
 Parenthesized values for group I ffiHimaiixe responses after being
 shown Exhibit A. Perceived risk decreased for 21 of 30 subjects,
 remained the same for 9 subjects, and increased for 0 subjects. Two
 subjects changed their assignments torn guilty to not guilty.
generally concluded that the risks to school children are
quite small, far lower than the risks to workers who are
called upon to remove the asbestos."01 The data shown
in Table ni suggest that this "small risk" does not ap-
pear small or acceptable to people when presented as a
single estimate (0.23 fatalities per million students). The
results show how sensitive perceptions of risk and guilt
are to contextual information provided by a simple table
of comparisons and to a  critique that  undermines the
legitimacy of inferring acceptability of risk  from com-
parisons across diverse hazards.
     The results of this modest empirical  study should
be interpreted with caution. The trial setting was artifi-
cial and the arguments were quite abbreviated selections
from the many possible ways of presenting, challenging,
and counterchallenging the information about asbestos
risks. The few prior attempts to examine the content of
risk messages, going back to Fischhoff <"> and including
the study by Roth et a/., are  similarly incomplete —
more on the order of demonstration studies.  Despite being
incomplete,  these studies do demonstrate that content
and context matter in risk communication.  If we take
this message seriously, we should incorporate a carefully
designed and executed evaluation component into every
important communication effort.
     Recognizing the limitations of our simulated trial,
it  still seems remarkable  to  us that  the  effects of the
comparisons in Exhibit A were so easily offset by the
critique despite the fact that they  show the asbestos risk
to be minuscule  relative  to other commonly accepted
risks. This suggests to us that the analyses and opinions
of technical experts who believe that asbestos in schools
should be left in  place may aot be  convincing  to the
public ia in adversarial context. More generally, the
impotency of quantitative risk assessment  in adversarial
settings has important implications for  the way that we
manage risk in our society. One implication is that those
who assess and manage risks need to  relate to their con-
stituents over the long term in ways that establish trust,
credibility, and mutual respect.
     In summary, the simplicity and  intuitive appeal  of
comparisons of unrelated risks may be highly deceptive.
Many factors appear to play a role in determining whether
such comparisons will be useful. Whether  these kinds
of comparisons ultimately generate more light than heat
will depend on the degree to which both the context of
risk communication and the content of the messages are
sensitive to those factors.

                      We are indebted to numerous individuals for their
                 assistance with the asbestos trial simulations. In partic-
                 ular, we wish to thank Deny Allen, Kenny S. Crump,

                                                                                                            Slovic et al.
Fred  Fields, and  William Suojanen, without implying
that they necessarily  concur in our research  design 'or

 1.  E. Roto, G. Morgan, B. Rschboff, L. Live, sad A. Bosnia,
    "What Do We Know About Miking Riik Comparisons?" Risk
   Anafytit 10, 375-387 (1990).                v
 2.  F. D. Sowby. "Radiation and Other Risks." HtatA Physio 11,
 3.  N. Rothschild, "Osmiag to Crip* with Risk" (Address presented
   oo BBC television, November 1978; reprinted  in toe Wail Sara
   Journal, M*y 13,1979).
 4. B. Cohen, md I. Lee, "A Catalog of RisfcV HtaUt Phyjia 3C.
   707-722 (1979).
 5. P. Slovic, "Perception of Risk." Science 36. 280-285 (1987).
 6. Editorial, "Rothsdiild'i nimerue •noguce," Nanirt, 276, 429
 7. V. T. Covello. P. M. Ssndman, and P. Slovic, Ritk Communi-
    cation, Risk Stanoici and Risk Comparisons: A Manual for Plant
    Managers (Wubiogton,  D.C, Qiemical Manufscturen Auoci-
    •lion. 1988).
 8. E W. Liwien, M. V. Jones, tad R. M. Jones, Comparative Ritk
    Antstmtnt: Towards aad Analytical Framework (Kiniai City.
    Midwest Reieircb Instiute. 1984).
 9. E. E. Poenin, "The Accepunee of Risk," British Medical Bui-
    lean. 31, 184-190 (197S).
10. B. T. Mossman. J. Bignon. M. Com. A. Sciton, isd J. B.  L.
    Gee, " Asbestos;  Scientific Devtlopmena and Implications for
    Public Policy," Jttenc* 147. 294-301.
11. B. Ftschhoff. In R. Ktspenon tad R. W. Kales (eds.), Equity
    * Main, 1981).

Office of
Some Notes on
Environmental Risk
Peter M. Santfnten
November 1986

                                         L  EnvuoMMaul rick t* not •bi(iu>y
X Baportafi BBE
4. 7lMh*k*ti»yii«iDpliAe4iu»a dichotomy
1 IU|MflmtiytopmOBuiuifc«ri*kttory
4 Claims of ruk in
                                                           s lot BKMthu mortality (Utuiid
                                         1  PoBey itariainm «r» »»«» M «ith«r ri»hy or tutt
                                         4.  Equity cod control tuuMui»d*riM most nak<
                                         1  Ri«hd«ciMaM«vb«a«r«rlMaUM public iluf«»th«|w»*r

                                      an MM M bfktimau.
                 'Eiplaioiat Envgonineaul Riifc  Some Ndtei oo EawMmeaul Risk Coimnuaieaiioa.'  by PHUT M.
                 Office. Office of Toiic Subnaace*. U5. Eavmanettil PTOUOIOB Agency. Novembo 1986.
                                                           (or die TSCA Aiinu
                     "Important  If True"
                     In colonial times newspaper "correspondents" were nothing
                     more than acquaintances of the publisher, writing home from
                     their travels. Unable to confirm or disconfirm their reports.
                     cautious publishers often printed them under the headline
                     "Important If True."
                       "Explaining Environmental Risk" should be read in the
                     spirit of this caution. While I have leaned heavily on-the risk
                     communication research literature where I could, many
                     questions haven't been thoroughly studied, and ban I have
                     relied on my experience, my sense of other people's
                     experience, and. frankly, my biases. If your experience and
                     biases suggest different answers, try them. If you want to
                     stick more closely to research findings, check the sources   •
                     listed at the end.
                       Why are so many risk assessment and risk management
                     people beginning to take an interest in risk communication?
                     There are two answers. I think, one entirely admirable and
                     the other more open to question. The good news is that
                     experts and managers are coming to recognize that how
                     peapia perceive a risk determines how they respond ta it.
                     which in turn  sets the context for public policy. It. is hard to
                     have decent policies when the public ignores serious risks
                     and recoils in  terror from less serious ones. The task of risk
                     communication, then, isn't just conveying information.
                     though that alone is a challenge; it is to alert people when
                     they ought to be alerted and reassure them when they ought
                     to be reassured. If your job is directing the cleanup at
                     chemical spills, or running a right-to-know program, or siting
                     new waste facilities—in fact, if your job has anything to do
                     with setting or administering or following environmental
                     regulations—explaining environmental risk is an important
                     piece of your job. And it's probably a piece for which you
                     have had little training.
                       The more questionable reason for the growing interest in
                     risk communication is the hope in some quarters that
                     communicating about the environment can somehow replace
                     managing it or regulating it aggressively. This is a common
                     dilemma for communication specialists—advocates of bad
                     policies sometimes imagine that they can get away with
                     anything if they sellit cleverly enough, while advocates of
                     good policies sometimes imagine that they don't have to sell
                     at all. At a January 1986 national conference oa.nsk.
                     i iimiiiiiMM jtimi |co*4ponsQr0a by the Conservation"
                     Foundation, the National Science Foundation, the
"Explaining EaviroDmeatal Risk: Some.Note* oo Eavireomeotil Riik Communication,* by Peter M. Sudnua for the TSCA Assistance
Offict. Office of Toxic Substances. U.S. Environmental Preuoioa Agency, November 1986.

                      Environmental Protection Agency, and other organizations),
                      the sessions on how to alert people to serious risks were
                      sparsely attended, while overflow crowds pondered ways of
                      Miming people down. People sometimes need to be calmed
                      down—but the ultimate goal of risk communication- should
                      be rational alertness, not passive trust.
                         If • public that views risk with rational alertness strikes
                      you as a desirable outcome, "Explaining Environmental Risk"
                      should  help. This is neither a theoretical treatise nor a
                      nitty-gritty cookbook; along with the practical suggestions for
                      effective communication, I  have tried to explain why some
                      strategies work and others fail, so that you can build on this
                      understanding to design your own strategies.
                         Though I hate to admit it, risk communication is a simpler
                      field *h*" r^«it- assessment or risk management. It just isn't
                      that hard to understand how journalists and nontechnical .
                      publics think about risk. But it is crucial to understand, and
                      not mastering the rudiments of risk communication has led a
                      lot of smart people to make a lot of foolish mistakes. With
                      apologies to busy readers, 1 have therefore resisted the urge
                      to produce an executive summary or a list of
                      recommendations. Technicians can get by on cookbooks,
                      perhaps, but decision-makers need to understand.
                        Much depends, in fact, on whether you think risk
                                     is a job th*M ****** safely be left to
                      officers) or whether— as I am convinced— you believe it must
                      become an integral part of risk management. Although I hope
                      public Information people will find some value in what I
                      nave to say. my main goal is for environmental protection
                      commissioners and plant managers to read it ... not merely
                      pass it along to the public information office.
                        The temptation to pass it along to the public information
                      office— end then forget it— is almost overwhelming, I know.
                      It's not just that decision-makers are busy people. It's not
                      even that decision-makers don't realize how greatly their
                      success depends on dealing effectively with the media and
                      the public It's more that they wish it weren't so, that dealing
                      with the media and the public seems in so many ways the
                      least pleasant, least controllable, least /air part of their work.
                      Most risk managers. 1 suspect, spend a good deal of time
                      hoping the media and the public wilt  go away and .leave
                      them to do their jobs in peace.
                        But since they won't, the next best thing is to understand
                      better why they won't, how they an likely to react to what
                      you have to say. and what you might want to say differently
                           time. I hope "Explaining Environmental Risk" will help.
•E*I>i«i«-t EavinMnrau! Risfc Some Naa oa Eaviraunenul Risk
Office. Office erf Toxic SnbHuce*. US. Eavaomnemal Prelection Agency.
 by Peter M. Siadjnu for the TSCA

                        Four on-going research projects have added greatly to my
                      understanding of risk communication. They are: (1)
                      "Environmental  Risk Reporting" and "Risk Communication
                      for Environmental News Sources" (with David B. Sachsman,
                      Michael Greenberg. Audrey R. Gotsch, Mayme Jarkat, and
                      Michael Gochfeld). both funded by the National Science
                      Foundation Industry/University Cooperative Center for
                      Research on Hazardous and Toxic Substances; (2) "Getting to
                      Maybe: Building Toward Community-Developer Negotiations
                      on New Hazardous Waste Facilities" (with Jim Lanard and
                      Emilie Sdu&eidler). funded by the Fund for New Jersey; (3)
                      "Manual and Conference for DEP Risk Communication" (with
                      Caron Chess and B.J. Hance), funded by the New Jersey Spill
                      Fund, New Jersey Department of Environmental Protection:
                      and (4) "Radon Risk Communication Symposium and
                      Recommendations" and "Radon Knowledge, Attitudes,  and
                      Behavior in New Jersey" (with. Neil Weinstein). both funded
                      by the  New Jersey Department of Environmental Protection.
                      Of course my colleagues and funders on  these projects  are
                      not responsible for my speculations in this report.
                        Several organizations have invited me  to address them on
                      strategies of risk  communication, providing an opportunity to
                      develop the ideas expressed in this report and test them on
                      thoughtful and experienced audiences. I  am grateful
                      especially to the National Governors' Association, the New
                      Jersey Hazardous Waste Facilities Siting Commission, the
                      Council of Scientific Society Presidents, the Institute for
                      Environmental Studies of the University  of North Carolina.
                      and the Air Pollution Control Association.
                      Peter M. Sandman is Professor of Environmental Journalism
                      at Cook College, Rutgers University. New Brunswick, NJ, and
                      Director of the Environmental Communication Research
                      Program of the New Jersey Agricultural Experiment Station.
                      Preparation of this report was funded by the Office of Toxic
                      Substances of the United States Environmental Protection
                      Agency as  part of the Agency's effort to obtain diverse views
                      on risk communication. Publication of this document does
                      not signify that the contents necessarily reflect the views and
                      policies of the Agency.
*EipUiaia« Envnonnvaul Risk: Some Notes oa Environment*! Risk Communiciuoo." by Peter M. Sudouo for (he TSCA Aitisuncr
Office. Office of Toxic Sutasuaces. U.S. Envuonmeoul Protection Agency, November 1986.

                      Dealing With The Media
                      1. Eavin
atal risk Is not • big story. The mass media are
                      not especially interested in environmental risk. Reporters do
                      care whether or not an environmental situation is risky:
                      that's what makes it newsworthy. But once the possibility of
                      hazard is established — that is. once someone asserts the risk
                      on the  record— (he focus turns to other matters: how did the
                      problem happen, who is responsible for cleaning it up. how
                      much will it cost. etc. Assessing the extent of the risk strikes
                           journalists as an academic urtorcigfr The reporter's job is
                      news, not education; events, not issues or principles. And
                      the news is the risky thing that has happened, not the
                      difficult determination of how risky it actually is.
                        In an emergency, of course, the extent of the acute risk is
                      the core of the story; radio reporters in particular want to
                      know first and foremost whether to tell listeners to stay
                      indoors, to evacuate, not to drink the water, etc. But the
                      media don't especially want to know the ins-and-outs of risk
                          unent. the details of how great the risk is likely to be.
                      bow sun the experts are* ox haw they found: oat. if the'story
                      is important enough, these technical details, merit a
                      follow-up, a sidebar on the third or fourth day—but few
                      stories are Important enough.
                        The typical news story on environmental risk, in other
                      words, touches on risk itself, while it dwells on more
                      newsworthy matters. In 1985 newspaper editors in New
                      Jersey were asked to submit examples of their best reporting
                      on environmental risk, and the articles were analyzed
                      paragraph by paragraph. Only  32 percent of the paragraphs
                      dealt at all with risk. Nearly half of the risk paragraphs,
                      moreover, focused on whether a substance assumed to be
                      risky was or was not present (e.g. is there dioxin in the
                      landfill), leaving only 17 percent of the paragraphs that dealt
                      directly with riskiness itself (e.g. how hazardous is dioxin).
                      In a parallel study, reporters were asked to specify which
                      information they would need most urgently in covering an
                      environmental risk emergency. Most reporters chose the basic
                      risk information, saving the details for a possible second-day
                      story. What happened, how it happened, who's to  blame, and
                      what the authorities are doing about it all command more
                      journalistic attention than toxicity during an environmental
"ExpUisint Envirofiinemal Risk: Some Sout on Eavifonmeatal Risk Conn
Office. Office of Toiie Sabnaace*. VS. Eavirowneaul Pimeoion Afeacy. November 1986.
                      by Peter M Sandman for (he TSCA Assistance

                         The nature of (he crisis determines how much stress the
                       media put on risk as opposed to other issues. Reporters
                       know, for example, that a chemical spill is a risk story, and
                       at the scene of a spill they will keep asking about toxic
                       effect* even alter they are told the chemical is benign and
                       inert. A fire story, on the other hand, automatically raises
                       questions about how the fire started, how much damage was
                       done, who turned in the alarm, and the like: many reporters
                       won't realize unless told that a fire in a battery factory or a
                       supermarket warehouse is a toxic event. But even when
                       reporters understand that environmental risk is a key element
                       of the crisis, their appetite for risk information is strong but
                       easily sated; they want to  know badly, but they don't want to
                       know much.
                        And when there is no crisis? The extent of a chronic risk is
                       newsworthy only when events make it so—for example,
                       when a court battle or a regulatory action hinges on a
                       disputed risk assessment.  Sources wishing to "sell" a chronic
                       risk story to the media must therefore work to make it
                       newsworthy. Give it a news peg—that is. make something
                       happen that reporters can  cover. Make it interesting. Build
                       the case for its importance. Provide a prop worth focusing a
                       camera on. But expect only partial success; reporters flock to
                       the scene of a crisis, but they have to be seduced into
                       covering chronic risk.
                        Among the greatest environmental risks in New Jersey is
                       indoor rwkm contamination. Because it is new and serious, it
                       received considerable media attention in 1985 and early
                       1986. Then the coverage began to slip. The easy news pegs
                       were over the discovery of the problem, the first home in the
                       state with a super-high reading, the passage of radon
                       legislation. With no "radon industry" to fight back, the
                       conflict that journalism feeds on has been conspicuously
                       missing from the radon story. Radon is more a health
                       problem and a housing problem than an environmental
                      Cjontroveny, and its coverage if correspondingly muted. And
                       radon at least has the "advantage" of cancer, the disease we
                       love to hate. Imagine its low visibility if it gave people
                      emphysema instead.

                       2.  Politics !• more newsworthy than science. The media's
                      reluctance to focus on risk for more than a paragraph or two
                      might be less of  a problem if that paragraph or two were a
                      careful summary of the scientific evidence. It seldom is. In
                      fact, the media are especially disinclined to cover the science
                      of risk. Most of the paragraphs devoted to risk in the New
                      Jersey study consisted of unsupported opinion—someone
                      asserting or denying the risk without documentation. Only
                      4.2 percent of the paragraphs (24 percent of the risk
                         ignph*) took an iniemndiale or muted or tentative
•E»pU»aiaj Eovmwneaul Riik: Some Noui OB Eavinameeul Risk Coounuaicuioo.' by Peur M. Sudraaa for the TSCA
Office, Office of Toxic Sutauaees. U.S. Eavaoaneoul Proieaioa Agency. November 1986.

                       position on the extent of the risk. And only a handful of the
                       articles told readers what standard  (if any) existed for the
                       hazard in question, much less the status of research and
                       technics! debate surrounding the standard.
                         To* media's focus on the politics of risk rather than the
                       science of risk is most visible in the sources relied upon in
                       risk coverage. Irr the New Jersey study. 57  percent of the
                       sources cited were government, with state  government (22
                       percent) leading the pack. Industry captured IS percent of
                       the paragraphs; individual citizens  and advocacy groups
                       were cited in 7 percent each. Uninvolved experts such as
                       academics—those least likely to have an axe to grind, most
                       likely to have an intermediate opinion and a technical basis
                       for it—were cited in only 6 percent of the paragraphs. Of
                       course sources from government, industry, and
                       euiuuiunental groups may also hare- scientific rationales for
                       their judgments, and "experts" an  not always neutral. Still, it
                      . is important that the media get their risk information from
                       people who are directly involved in the news event: only
                       occasionally do they seek out uninvolved experts for
                       guidance on the extent of the risk.
                         Trying to interest journalists in the abstract issues of
                       environmental risk assessment is even tougher than trying to
                       get them to cover chronic risk: abstract issues are not the
                       meet of journalism. Yet the public needs to understand
                       eburattiuia like the uncertainty of  risk assessments, the
                               iirty or zero risk, the debatable sssuiuutiuiis
                      underlying dose-response curves and animal tests. Where
                      possible, it helps to embed some of these concepts in your
                      comments on hot breaking stories—though reporters and
                      editors will do their best to weed them out. When there is no
                      breaking story, try to sell your favorite reporter on a feature
                      on the fight over how conservative risk assessment ought to
                      be. Emphasize that the problem underlies many of the stories
                      be or she is covering. But understand why you will have
                      only partial success, why the science of risk is inevitably less
                      newsworthy than the politics of risk.

                       3. Reporters cover viewpoints, not "truths." Journalism, like
                      science, attempts to be objective, but the two fields define
                      the term very differently. For science, objectivity is
                      tentativeness and adherence to evidence in the search for
                      truth. For journalism, on the other hand, objectivity is
                      balance. In the epistemology of journalism, there is no truth
                      (or at least no way to determine truth); there are only
                      conflicting claims, to be covered as fairly as possible, thus
                      tossing the hot potato of truth into the lap of the audience.
                        Imagine a scale from 0 to 10 of ail possible positions on an
                           : Typically, reporters give short ahrift to u, 1.9. and 10:
'ExpUiaist Envimaneaul Risk Some Notei oa Environroeoul Risk Co
by Pew M. Saataia for the TSCA Assistance
Office. Office of Toxic Subnaaces. U.S. Eavimiaeaial Proteoioo Agency, November 1986.

                       these views are too extreme to be credible, and are covered
                       as "oddball" if they are covered at all. (You may think some
                       pretty extreme viewpoints get respectful media attention—
                       but you haven't met the people reporters decide
                       not to quote.) Reporters also pay relatively little attention to
                       4. 5. and 6. These positions are too wishy-washy to make
                       good copy; how do you build a story out of "further research
                       is needed?" And sources with intermediate positions are
                       unlikely to be heavily involved in the issue, certainly
                       unlikely to seek media attention. Most of the news. then.
                       consists of 2's and 3's and 7's and 8's. in alternating
                       paragraphs if the issue is hot; otherwise in separate stories as
                       each side creates and dominates its own news events.
                       Objectivity to the journalist thus means giving both sides
                       their chance, and reporting accurately what they had to say.
                       It does not mean filling in the uninteresting middle, and it
                       certainty does not mean figuring out who is right. Journalists
                       who insist on trying to figure out who is right are encouraged
                       to become columnists ... or to leave.      \
                         If a risk  story is developing and you have a perspective
                       that you feel has not been  well covered, don't .wait to be
                       called. You won't be. And you don't need  to wait. Reporters
                       are busy chasing after the sources they hove to talk to. and
                       listening to the sources who wont to talk to them. If you're in
                       the former category—if you're safety ™a«ag«f at a plant that
                       just experienced  an uncontrolled release, for example-
                       reporters will find their  way to you. like it or not.
                       Otherwise, rather than suffer in silence, become one of the
                       relatively few experts who keep newsroom telephone
                       numbers in their rolodex.  You will find reporters amazingly
                       willing to  listen, to put you in their rolodexes. to cover your
                       point of view along with all  the others. Insofar as you can.
                       try to be a 3 or a 7—that. is. a credible exponent of an   >.  ;
                       identifiable viewpoint Don't lei yourself be 'pushed to a
                       position that is not yours,  of course, but recognize that
                       journalism doesn't trust  O's and 10!s. and has little use for
                         In deciding whether to brave the considerable risks of
                       media exposure,  bear in mind that the story tvill be covered.
                       Whether or not you arrange to be included. News items are
                       allotted media attention to the extent that journalists see
                       them as important and interesting. Then the search begins for
                       information  to fill the vacuum—preferably new. solid.
                       comprehensible information that reflects an identifiable'point
                       of view, but if there's not enough of that to fill the time or
                       space that the story "deserves." reporters will scrounge for
                       angles to make up the difference. The .result can be an
                       enlightening, feaiuxe an the problems of technical prediction.
                       but it's mom likefv to be a "color stonr"—the feer* of
"Explaining Environment*! Ruk: Some Notes on EaviraoiMaul Riik Communication." by Peter M. ^•n^mnn .jt the TSCA
Office, Office of Toxic Subsuacei, VS. Environment*! Proteoioo Agency, November 1986.

                      bystanders, the views of ideologues, the speculations of
                      spokespeople. the history of mismanagement. Environmental
                      risk stories often turn into political stories in part because
                                      ij more readily available' than technical
                      content. Experienced sources work at filling- the vacuum*.
                        Although journalists tend not to believe in
                      TrauVwiuWcapital-T. they believe fervently in facts. Never
                      lie to • reporter; Never guess. If you don't know, say you
                      don't know. (But expect reporters to ask why you don't
                      know.) If you don't know but can find out later, do so, and
                      get back to the reporter as soon as possible, remembering that
                      journalistic deadlines are measured in minutes, not months.
                      If you  know but can't tell, say you can't tell, and explain
                      why. If you know but can't manage to say it in English, find
                      •ox&eooet who can. Reporters do not expect you to be neutral;
                      in fact, they assume that you probably have an axe to grind,
                      and prefer that you grind it visibly. They do expect you to
                           it with integrity.
                       4. The risk story is simplified to a dichotomy. The media
                      see environmental risk as a dichotomy; either the situation is
                      hazardous or it is safe. This is in part because journalism
                      dichotomizes all issues into sides to be balanced. But then
                      an other reasons for dichotomizing risk. (1) It is difficult to
                      find space for CTmpl *K «•••* 1* *
                      SOOZEM SB naiWCXeeiPCDx 3 Of T.I
"ExpJ«n«ttt Eavraraeaul Ride Some Noi» OB Eavinoneaul Risk Commneiciuoa.' by Peur M. Sudmu for the TSCA Asiuunce
Office. Office of Toxic Substances, US. EaviroiuneaUl Protection Agency. November 1986.

                        Sources, especially technical sources, greatly resent the
                      pressure from journalists to dichotomize and simplify. The
                      dichotomization of risk distorts the reality that nothing is
                      absolutely safe or absolutely dangerous, and polarizes
                      "more-or-less" disagreements into "yes-or-no" conflicts. And
                      oversimplification of any sort can mislead the audience and
                      damage the reputation of the source. But recognize that
                      journalists must simplify what they cover. If you refuse to
                      simplify what you say, the reporter will try to do the job for
                      you (at great risk to accuracy) or will turn to a more
                      cooperative source.
                        The most qualified person to simplify your views is you.
                      Decide in  advance what your main points are, and stress
                      them consistently and repetitively, even if you have to hook
                      thotn onto your answers to irrelevant questions. Laave out
                      the technical qualifiers that your colleagues might insist on
                      but the general public doesn't need to know (but leave in the
                      qualifiers that really affect the bottom line). Stay away from
                      jargon, and explain the technical terms you can't avoid.
                      Check to make sure the reporter understands what you are
                      saying: if the reporter looks glassy-eyed or starts frantically
                      taking down every word, back up and start over.
                        When you explain the significance of a toxic substance to
                      reporters,  try to avoid the "is it there or not" dichotomy,
                      which can so easily alarm people about tiny concentrations.
                      On the other band, don't expect reporter* to. ail still foe a
                      dissertation on uncertainty in dose-response curves. Your
                      best bet. when you can. is to specify the amount involved.
                      then set it against some standard of comparison, ideally a
                      government exposure standard. This is still a dichotomy, of
                      course; it leaves  the misimpression that exposures just under
                      the standard are perfectly safe while exposures just over are
                      deadly. But as dichotomies go. "over or under" is preferable
                      to "there or not."
                        If you want to fight the journalistic tendency to
                      dichotomize risk, fight it  explicitly, asserting that the issue is
                      hot "risky or not" but "how  risky." Recognizing that
                      intermediate positions on risk are intrinsically less dramatic
                      and more complex than extreme positions, work especially
                      hard to come up with simple, clear, interesting ways to
                      express the middle view. Even so. expect reporters to insist
                      on knowing "which side" you come down on with respect to
                      the underlying policy dichotomy.

                      S. Reporters try to personalize the risk story. Perhaps
                      nothing about media coverage of environmental risk so
                      irritates technical sources as the media's tendency to
                      p.t^nnaliM "Have you stopped drinking  it  yourself?"
                      "Would you. let jwnr family  tiv» thenT Such quartans fly in
'Explaining Eavirovneaul Riifc  Seme Note* on EavinanMttl Ritk Co
Office, Office of Toxic Suteuacei, US. Envireuneaul Protecuoo A|uey. November 1986.
l." by Peur M. Sandman for the TSCA Astusunrr

the face of the source's technical training to keep oneself out
of one's rewarch. and they confuse the evidentiary
requirements of policy decisions with the looser ones of
personal ^h""**^  But for reporters* n\"»«*""*T that personalize
are the best questions. They do what editors are constantly
asking reporters to do: bring dead issues to life, make the
abstract concrete, focus on real people facing real decisions.
Personalizing also forces the source to dichotomize, to make
the same "yea" or "nay" decision the reader or viewer must
  In a sense, experts and policy-makers work at a different
level of analysis than reporters and the public. As an EPA
study on the ethelyne dibromide controversy noted, the
agency wanted to talk about "macro-risk" {how many deaths
will result from EOB contamination), while reporters kept
asking about "micro-risk" (is it okay to eat the cake mix). The
connections between macro-risk and micro-risk are difficult
to draw. But for the individual citizen (faced with a cake
mix, not a regulatory proposal), micro-risk is the issue, and
reporters are not off-base in pushing technical sources to
trace the connections. This is what personalizing questions
are designed to do.
  Knowing that reporters will inevitably ask personalizing
questions, be prepared with answers. 11 is often possible to
answer with both one's personal views end'ana's policy
recommendations, and then to explain the difference if there
is one. Or come with colleagues whose personal views are
different, thus dramatizing the uncertainty of the data. If you
are not willing (or not permitted) to acknowledge your own
views, plan out some other way to personalize the risk, such
as anecdotes, metaphors, or specific advice on the individual
micro-risk level.

 6. Claim* of risk are usually more newsworthy than claims
of safety. On our O-to-10 scale of risk assertions, the 3's and
7's share the bulk of the coverage, but they don't share it
equally. Risk assertions receive considerably more media
attention than risk denials. Sometimes, in fact, the denials
get even less coverage than the intermediate position, and
reporters wind up "balancing" strong assertions of risk with
bland statements that the degree of risk is unknown. In the
New Jersey study, the proportions were 58 percent -'risky."
18 percent "not risky." and 24 percent mixed or
  This is not bias, at least not as journalism understands
bias. It is built into the concept of newsworthiness. If there
were no allegation of risk, there would be no story. That
something hem might be risky is thus the com of the story;
having conered it. the media give rather less attention to the
counterbalancing notion that it might not be risky.
*i«p'"Biat Eavironmemal Rut Some Notes am Envirooeaenttl Risk OMnmonicition." by Peter M.
Office. Office of Toxic Snhmmrt. U.S. Eavaoamcoul Protecuoa Agency. November 19&6.

  Other factors contribute to the tilt toward, alarming news.
 One is the reporter's desire to "build" the story, to come back
 with something that editors will want to showcase.
 (Reporters are much more interested in selling stories *k«n |Q
 "selling newspapers.") Another factor is the journalist's
 preference for simple, graphic language, for "dump" rather
 than "land emplacement." Risks sound riskier in simple
 language than in technical jargon. The factor closest to
 outright bias—but still distinguishable in the minds of
 journalist*—4s the media's traditional  skepticism toward
 those in authority. Most news is about powerful people, but
 •long with the advantage of access government and industry
 must endure the disadvantage of suspicion. Environmental
 groups, by contrast, receive less attention from the media, but
 th« attention is ""7** consistently friendly.
  On the other hand, the media are often and justly criticized
 for being too slow to alert the public to new environmental
 hazards. Considering that we rely largely on journalism as an
 "early warning system" for social problems on the horizon.
 this Is a serious criticism. To gain a journalistic hearing, the
 fint source to  assert a particular risk must  be reasonably
 credible, highly committed, and very lucky or very skilled.
 Almost invariably, new technologies start out with
 sweetheart coverage. The environmental controversy comes
 later, and only after the controversy is on the media agenda
 (and the *irrhTnrlfTgy is r**^**!** tno deeply embedded to be
 dislodged) does the risky side of the argument catch up and
 pull ahead. This may be the worst of all possible patterns: to
 fail to warn us about risks when it's early enough to make a
 societal go/no-go decision, then to frighten us deeply about
 risks after the decision has been made.
  The principal exception to this pattern is emergencies. On
 a chronic risk  story, the risk is the story. But a genuine
 emergency is by definition a big story: freed from the need to
 build the- story, the  reporter—especially the local reporter-
 may try to prevent panic instead. The  President's
Commission on the  Accident at Three Mile Island conducted
 a content analysis of network, wire service, and major
 newspaper coverage during the fint week of the 1979
 accident. The Commission's expectations of sensationalism
 were not confirmed. Of media passages that were clearly
either alarming or reassuring in thrust. 60 percent were
 reassuring. If you stick to the technical issues, eliminating
 passages about inadequate flow of information and general
expressions of fearfulness from local citizens, the
preponderance of reassuring over alarming statements
becomes 73 percent to 27 percent.  .
  It didn't seem that way at the time, of course. The
                   ntninaj pmrknuly aesvneo to ovsefe*
may or may not be hazardous naturally strikes people as
                  Mil Risk Corn*
"Explainiai Eavirootteftul Risk: Some Notes oa Envin
Office. Office of Toxic Substances, U.S. Eavoouneaul Protection Agency. November 1986.
by Peter M. fl-r'r lor (he TSCA Auisuoce

                      alarming, almost regardless of the amount of attention paid to
                      the two sides; imagine reading this evening that scientists
                      disagree over whether your favorite food is carcinogenic.
                      Thus* sociologist Allan Mazut has found that public
                      tearfulness about risky new technologies is proportional to
                      the amount of coverage, not to its character. Media coverage
                      of environmental risk alerts the public to risks it was
                      otherwise unaware of. and thus increases the level of alarm
                      even when it is balanced.
                       . None of this is a rationale for avoiding the media. Even
                      balanced media coverage may not reliably lead to balanced
                      public opinion, but balanced  coverage is preferable to  .
                      unbalanced coverage. And the coverage is most likely to be
                      balanced when sources on all sides are actively trying to get
                      covered- People with knowledge and opinions to share
                      perform a public service when they share them. What can
                      you do to alert people to the risks of a new technology before
                      it is too late? What can you do to redress the alarming
                      imbalance once the media have begun to overdramatize the
                      risks? Energetic public relations will help with both tasks.
                      though in both cases you will be working against the grain.

                       7. Reporter* do their jobs with limited expertise  and time.
                      At all but the largest media, reporters covering environmental
                      risk ate not likely  to have any special preparation  for the
                      assignment. Specialized environmental reporters are more the
                      exception than the rub. Reporters covering an environmental
                      emergency, for example, are mostly general-assignment
                      reporters or police reporters,  sent to the scene (or the phones)
                      without time to scan the morgue, much less a technical
                      handbook. And reporters tend to be science-phobic in the
                      first place; the typical college journalism major takes only
                      two science courses, and chooses those two carefully in an
                      effort to avoid rigor. Though  there are many exceptions, the
                      avenge reporter, approaches a technical story with
                      trepidation (often  hidden by  professional bravado), expecting
                      not to understand.
                         It doesn't help that the average reporter covers and writes
                      two to three stories a day. Here loo there are exceptions, but
                      most journalists are in a great hurry most of the time. They
                      must make deadline not just  on this story, but quite often on
                      the story they will be covering after this one. Their goal.
                      reasonably, is not  to find out all that is known, but just to
                      find out enough to write the  story. Even if they knew more.
                      they would not have the space or airtime to report more, nor
                      do they believe their readers  or viewers would have the
                      interest or patience to absorb more.
                         Note also that irrespective  of what journalistic superstars
                      earn, that avengs reporter at a small daily newspaper takes
                      home perhaps $13.000-$! 8,000 a year. Considering their
"ExpUioiag Eovinnineettl Riifc Some Now* am 1
Office. Office of Toxic Subnucex. U.S. Eaviroamemal Protection Agency. November 1986.
by Peur M. Sudmaa for the T5CA Auiiuocr

                       incomes, journalists are shockingly competent and dedicated.
                       but there are limits to how much competence and dedication
                       a salary in the teens can purchase.
                         if the idea appeals to you. by all means offer to teach local
                       journalists the basics of your field—but don't expect general
                       assignment reporters to find  much time (or much
                       stomach) for technical training they will use only a few times
                       a year. A beat reporter who covers your issue full-time (if
                       you are lucky enough to have one) is a much better candidate
                       for technical training.
                         Better still, train yourself (and your colleages and staff) in
                       dealing with the media. Hiring effective public information
                       specialists also helps, but reporters much prefer to talk to the
                       people in charge and the people in the know. Especially
                       during an emergency, press calls often go to the boss and the
                       expert instead of the press office, so the boss and the expert
                       should know how to talk to reporters. The annals of risk
                       communication are full of  stories of corporate managers and
                       agency bureaucrats who shot themselves in  the foot—and
                       permanently damaged their organizations—because they
                       hadn't the least idea of how  to deal with the media. Even the
                       best communication skills  can't rescue a technical disaster, of
                       course: who wants to handle the PR at Chernobyl or Bhopal?
                       But inadequate communication skills can create a disaster
                       that needn't have been.
                         And adeo^wle-communication skills are not so ban) to
                       develop. All it takes is a little understanding of how the
                       media work; a little training  in dealing with reporters, and a
                       little experience to smooth out the rough edges. Why. then.
                       do so many managers, bureaucrats, and technical experts
                       avoid all contact with the media? Because it's risky.
                       Reporters don't always understand what  you're telling them:
                       they  don't always share your goals and values:  they don't
                       always handle their  jobs the way you want them to. In all
                       these ways and many others, reporters may  be different from
                       the people you usually work with. And so.working with
                       reporters may sound  like something less  than an unalloyed
                         Pleasure or not. the risks of ducking the media are far
                       greater than (he risks of working with them. Every news story
                       about environmental  risk is a collaboration between the
                       journalists working on the  story and the sources they talk to.
                       There's not too much you can do to change  the nature of
                       journalism or the performance of journalists. But you can
                       understand them and figure out how  to deal with them. By
                       improving your own performance as a source, you con bring
                       about a real improvement in media coverage of
                       environmental risk.
'Explaining Environmental Ritfc: Some Hate* on Environmental Risk Communication.* by Pcur M. Sandman for the TSCA
Offiee. Office of Toiic Subcuoces. US. Environmental Prowoio* Afcscy. November 1986.

                      Dealing With The  Public

                      1. Risk perception is a lot more than mortality statistics, if
                      death rates are the only thing you care about, then the public
                      is afraid of the wrong risks. That is. public fears are not well
                      correlated with expert assessments or mortality statistics.
                      This is often seen as a perceptual distortion on the part of
                      the public, but a more useful way to see it is as an oversim-
                      plification on  the part of many experts and policy-makers. In
                      other words, the concept of  risk  means a lot more than
                      mortality tW*f*k"T
                        Virtually everyone would rather drive home from a party
                      on the highway than walk home on deserted streets. Even if
                      we do not miscalculate the relative statistical likelihood of a
                      fatal mugging  versus a fatal car crash, the possibility of
                      getting mugged strikes us as an outrage, while we accept the
                      possibility of an auto accident as voluntary and largely
                      controllable through  good driving. (Eighty-five percent of all
                      driven consider themselves better than average.) Similarly, a        ^
                      household product, however carcinogenic, seems a lot less
                      risky than a high-tech hazardous waste, treatment
                      fariUty the fanner is *"»•"'"«• and under one's own control,
                      while the latter Is exotic and controlled by others.
                        Risk perception experts (especially psychologists Paul
                      Slovic, Sarah Ltchtenstein. and Baruch Fischhoff) have spent
                      yean studying how people interpret risk. The following list
                      identifies some of the characteristics other than mortality that
                      factor into our working definitions of risk.  Remember, these
                      an not distortions of risk; they are part of what we mean by
                      the term.
                                                       Mar* Risky
                  Voluntary                            Involuntary
                  Familiar                             Unfamiliar
                  Controllable                          Uncontrollable
                  Controlled by self                     Controlled by others
                  Fair                                 Unfair
                  Not memorable                       Memorable
                  Not dread                             Dread
                  Chronic                              Acute
                  Diffuse in time and space              Focused in time and space
                  Not fatal                             Fatal
                  Immediate                            Delayed
                  Natural                              Artificial
                  Individual mitigation possible         Individual miiigatiair impassible
                  Datectabfo                            Undetectable

'Explaining Eavimmneaial Risk: Some News oe Environmental Riifc Commtuucanon,* by Peter M Sudnun for the TSCA Auisuncr
Office, Office of Toiic Suteunctt. U.S. Eavawmienul Prweauoo Agency. November 1986.  "

                        The very same risk—as experts see these things—wilt be
                      understood quite differently by the lay public
                      depending on where it stands on the dimensions listed
                      above. Some thirty percent of the homes in northern New
                      Jersey, for example, have enough radon seeping into their
                      basements to pose more than a one-in-a-hundred lifetime risk
                      of lung cancer, according to. estimates by the U.S.
                      Environmental Protection Agency and the State Departments
                      of Health and Environmental Protection. But despite
                      considerable media attention (at least in the beginning), only
                      five percent of North Jersey homeowners have arranged to
                      monitor their homes for radon, and even among these few
                      the level of distress is modest—compared, say. to the
                      reaction when dioxin is discovered in a landfill, objectively a
                      much smaller health risk. State officials were initially
                      concerned about a radon panic, but apathy has turned out to
                      be the bigger problem.
                        The source of the radon in New Jersey homes is geological
                      uranium: it has been there since time immemorial, and no
                      one is to blame. But three New Jersey communities—
                      Montclair. Glen Ridge, and West
                      Orange—have faced a different radon problem: landfill that
                      incorporated radioactive industrial wastes. Though their
                      home readings were no higher than in  many homes on
                      natural hotspots. citizens in the three communities were
                      ffiifrip j and fotzfuL and they successfully demanded that
                      the government spend hundreds of thousands of dollars per
                      home to clean up the landfill. The state's proposal to dilute
                      the soil nearly to background levels  and then dispose of it in
                      an abandoned quarry in the rural community of Vernon has
                      provoked New Jersey's largest environmental demonstrations
                      in years, with thousands of residents swearing civil
                      disobedience sooner than let the trucks go through. In nearby
                      communities threatened by naturally occurring radon.
                      meanwhile, the concern is minimal.
                        It doesn't help to wish that people would confine their
                      definitions of risk to the mortality statistics. They won't.
                      Mortality statistics are important, of course, and policy-
                      makers understandably prefer to focus on the risks
                      that are really killing people, rather  than the risks that are
                      frightening or angering people because they are involuntary.
                      unfamiliar, uncontrollable, etc. But successful risk
                      commuication begins with the realization that risk perception
                      is predictable, that the public overreacts to certain sorts of
                      risks and ignores others, that you can know in advance
                      whether the communication  problem will be panic or apathy.
                      And since these differences between risks are real and
                      relevant, it helps to put them on the table. Merely
                      acknowledging that a risk seems especially fearful because M
        Environmental Riifc Some Noui on Eaviraamu! Riik Co
Office. Office of Toxic Sufanince*. U.S. Envmnneoul Protection Agency. November 1986.
by Peter M. Sudmu for the TSCA AM.

                       is unfamiliar or unfair wilt help. Doing something to remedy
                       the unfamiliarity or unfairness will help even more.
                         Just to make things more complicated, risk perception is
                       not linear, not for anybody. That is. you can't just multiply
                       how probable a risk is by how harmful it is to get how badly
                       people want to prevent it. (If you couid. there would be no
                       insurance industry and no gambling industry.) In general.
                       people will pay more to protect against low-probability loss
                       than to pursue low-probability gain—but if the price is  low
                       enough to be dismissed as negligible, even an infinitesimal
                       chance at a big payoff looks good.
                         Risk judgments are also very responsive to verbal cues.
                       Doctors, for example, are much more likely to prescribe a
                       new medication that saves 30 percent of its patients than one
                       that loses 70 percent of them. A pollutant or an accident that
                       will-eventually give cancer to 10.000 people sounds very
                       serious, but one that will add less than one tenth of one
                       percent to the national cancer rate sounds  almost negligible.
                       There is in fact no "neutral" way to present risk data, only
                       ways that an alarming or reassuring in varying degrees.
                        Finally, people's perception of risk is greatly influenced by
                             ial context. Our responses to new risks, in fact, are
                      largely predictable based on our enduring values and social
                      relationships. Do we like or dislike, trust or distrust the
                      people, ox fojlitu^iirnt whose TJflT'f""1* m putting us at risk.?
                      Do our friend* and neighbors consider the risks tolerable or
                      intolerable? An they enduring higher risks than ours, or
                      escaping with lower ones? All these factors, though they are
                      irrelevant to the mortality statistics, are intrinsic parts of
                      what we mean by risk.

                       2. Moral categories mean more than risk data. The public
                      is far from sun that risk is the real issue in the first place.
                      Over the past several decades our society has reached near*
                      consensus that pollution.is me .illy wrong—not just harmful
                      or dangerous, not just worth preventing when practical, but
                      wrong. To many ears it now sounds  callous, if not immoral.
                      to assert that cleaning up a river or catching a midnight
                      dumper isn't worth the expense, that the cost outweighs the
                      risk, that then an cheaper ways to save lives. The police do
                      not always catch child motesters, but they know not to argue
                      that an occasional molested child is an "acceptable risk."
                        Government agencies build their own traps when they
                      promulgate policy (and public relations) in the language of
                      morality, depicting food additives or chemical wastes or
                      polluted water as evils against which they vow to protect the
                      Innocent public. It is not at all obvious which environmental
                      "insults'* (another term with moral overtones! a society
                      should reject on moral grounds and which rt should aiiau
"Explaining Environmental Risk: Some Nout OB Environmental Risk Communication," by Peter M. *""»"«»" for the TSCA Assistance
Office. Office of Toxic Sutnuaeei. VS. Environmental Protection Agency. November 1986.

                       strictly in terms of impact. But an agency that presents itself
                       and its mission in moral terms should expect to be held to its
                       stance. And an agency that wishes to deal with
                       environmental risk in terms of costs-and-benefits instead of
                       good-*nd-evil should proceed gently and cautiously, aware
                       that it is tramping on holy ground.
                         Nor is morality the only principled basis for questioning
                       the costs-and-benefits premises of risk assessment, fust as the
                       moralist challenges the tightness of trading off certain risks
                       against costs or benefits, the humanist challenges the
                       coherence of the tradeoffs. How.  the humanist asks, can
                       anyone make sense of a standard that tries to put a cash
                       value on human  life? Or. indeed, of a standard that assumes
                       that a hundred widely scattered deaths per year are
                       equivalent to a one-in-a-hundred chance of obliterating a
                       commuoity of  10.000?
                         Similarly, the political critique of the premises of risk
                       assessment  begins by noting that "the greatest good for the
                       greatest number" has always been a convenient rationale for
                       the oppression of minorities. Democratic theory asserts that
                       individuals and groups should be free to bargain for  their
                       own interests,  and  should be protected from the tyranny of
                       the majority. There is nothing unreasonable about the
                       suggestion that equitable distribution of risks and
                       benefits— and of the power to allocate risks and benefits — is
                                  important jrm* the. auaiauzation of total  risk or
                       the maximization of total benefit. It may be efficient to dump
                       every environmental indignity on the same already degraded
                       community, but it is not fair.

                       3. Policy decisions are seen as either risky or safe* Like
                       the media, the public tends to dichotomize risk. Either the
                       risk is seen as very frightening, in which case the response is
                       some mix of fear, anger, panic, and paralysis: or the risk is
                       dismissed as trivial, in which case the response is apathy.
                         In their personal lives, people do not necessarily dichoto-
                       mize risk. Most of us are quite capable of understanding that
                       the picnic might or might not be rained out, that the boss
                       might or might not get angry, even that smoking might or
                       might not give us lung cancer. Of course quantified
                       probabilistic statements are genuinely hard to understand,
                       especially when the probabilities are small, the units are
                       unfamiliar, and the experts disagree. But beyond these
                       perplexities lies another issue of enormous importance to
                       risk communication. While people may (with difficulty)
                       master a probabilistic  risk statement that concerns what they
                       should do to protect themselves, they are bound to resist
                       probabilistic risk  statements that concern what others
                                              > do> 10 ptoted th**** On my own
        EawoameDUJ Risk Some Mole* CM En
(Mice. Office of Toxic Stibnuces, UJ5. Eaviramaeaul Protection Agency. November 1986.
by feu* M. Sttdmu for ihe TSCA Auisuoce

                      behalf. I may choose to tolerate a risk or to protect against it.
                      but for you to decide thai my risk is tolerable is itself
                      intolerable. Quantitative risk assessments, risk-benettl
                      calculations, risk-cost ratios, and risk-risk comparisons are all
                      hard to hear when we bear the risk and someone else makes
                      the decision.

                       4. Equity and control issues underlie most risk
                      controversies.  Trust and credibility are often cited as the key
                      problems of risk communication. Certainly few people trust
                      government and industry to protect them from environmental
                      risk. This is just as true of the passive, apparently apathetic
                      public as  it is of the activist, visibly angry public. The  former
                      is simply more fatalistic, more prone to denial, more
                      completely drowned in undiscriminating chemophobia. The
                      activist public, in other words, distrusts others to protect its
                      interests and thus chooses to protect its own. The far larger
                      passive public is passive not because it believes others will
                      protect its interests, but because it doubts it can protect its
                      own. Both publics listen to the reassurances of government
                      and industry—if they listen at all—with considerable
                         But to say that trust is the problem here is to assume that
                      the goal is a passive public that doesn't mind being passive.
                      U the goal la an actively mm-mmd public, thftn the. problem
                      Isn't that  people are distrustful, but rather that government
                      and industry demand to be trusted. Translate the question of
                      trust into the underlying issue of control: Who decides what
                      Is to be done?
                         Any environmental risk controversy has two levels. The
                      substantive issue U what to do; the process issue is who
                      decides. So long as people feel disempowered on the process
                      issue, they an understandably unbending on the substantive
                      issue, in much the same way as a child forced to go to bed
                      protests the injustice of bedtime coercion without
                      considering whether he or she is sleepy. U isn't just that
                      people oppose any decision they view as involuntary and
                      unfair, regardless of its wisdom: because the equity and
                      control issues come first, people typically never even ask
                      themselves whether they agree on the merits. Outraged at the
                      coercion,  they  simply dig in their heels. U is hardly
                      coincidental that risks the public tends to overestimate
                      generally  raise serious issues of equity and control, while
                      most of the widely underestimated risks (smoking, fat in  the
                      diet, insufficient exercise, driving without a seatbelt) are
                      individual choices.
                         Specialists in. negotiation and conflict resolution have long
                      ondetHoodtfaia-retHtomhip between mbsranttv* bauea and
                      the process issues of equity and control. Consider for
'Explaining Envtroomenul Risk: Some Note* oa Envir
il Risk Co
Office, Office of Toxic Sobcuncei. U.S. Environmental Protection Agency. November 1986.
by Peter M. fomJimn far the TSCA A«isu
                      example a community chosen by the state government to
                      "host" a hazardous waste incinerator. Justly offended at this
                      infringement of local autonomy, the community prepares to
                      litigate, frautiutty collecting aiiuiuuitkin on the
                      unacceptability of the site. Both their anger and the legal
                      process itself encourage community members to overestimate
                      the risk of the proposed facility, to resist any argument that
                      some package of mitigation, compensation, and incentives
                      might actually yield a net gain in the community's health
                      and safety, as well as its prosperity..
                       In interviews with community members faced with such a
                      situation, the control issue tends to overshadow the risk
                      assessment. But when citizens are asked to hypothesize a de
                      facto community veto and envision a negotiation with the
                      site developer, they become quite creative in designing an
                      agreement they might want to sign: emissions offsets.
                      stipulated penalties, bonding against a decline in property
                      values, etc. It is still too early to tell whether a negotiated
                      hazardous waste treatment facility  is feasible. But thinking
                      about such a negotiation becomes possible for community
                      members only when they feel empowered—that is. when the
                      issue of outside coercion has been  satisfactorily addressed.
                       On this dimension people's response to information is not
                      much different from their response to persuasion. We tend to
                      team for a reason   either we're curious, or we're commuted
                      to a> point of view efra looming for ammnrtioit. or we're*
                    ,  faced with a pending decision and looking for guidance.
                      These three motivations account for most
                      information-seeking and most learning—and none of them
                      exerts much influence when an individual citizen is offered
                      information about, say. a Superfund clean-up plan. A few
                      stalwart souls will read out of curiosity, though it won't take
                      much technical detail to put a stop to that. Activists will
                      scour the plan for evidence to support their position or for
                      evidence that their position wasn't property oonsiueied.
                      (Activists know what they think and believe they can make a
                      difference.) And those charged with litigating, funding, or
                      implementing the plan study it in order to do their jobs.
                       And the general public? Why leam if you feel powerless
                      do anything about what you have learned? On the other
                      hand, when the public has felt it was exercising real
                      influence on a decision—the ASARCO smelter in Tacoma
                      comes to mind—it has shown a surprising ability to master
                      the technical details, including risk assessment details.
                       Not that every citizen wants to play a pivotal role in
                      environmental decision. We have our own lives to lead, and
                      we  would prefer to trust the authorities. If the issue is
                      unimportant enough we often decide to trust the authorities
                      despite* our. neenrstioRsc if' the* om is ttffsut enouejit w
*ExpUiaiat Eavmmeaul Rufc Some Note* oo Eavmameaul Riik Comamaicatioa,'  by Peter M. Sutdmu for the TSCA Assituoec
Office, Office of Toxic Sabnuces, U.S. Envnonmeaul Pmcaioo Afeacy. November 1986.

                       may feel we have no choice but to trust the authorities, again
                       despite our reservations. The gravest problems of risk
                       communication tend to arise whea citizens determine that
                       dw issue is important, that the authorities cannot be trusted.
                       and that they themselves are powerless. Then comes the
                       backlash of outrage.

                       S. Risk decisions are better when the public shares the
                       power.  People learn more and assess what  they Iciarn more
                       carefully if they exercise some real control over the ultimate
                       decision. But this sort of power-sharing is. of course.
                       enormously difficult for policy-makers, for a wide range of
                       political, legal, professional, and psychological reasons.
                       Interestingly, corporate officials may sometimes find
                       power-sharing leas unpalatable than government officials.
                       Corporations have a bottom line to nurture, and when all else
                       fails they may see the wisdom of sharing power in the
                       interests of profit. But government officials have no profit to
                       compensate for the loss of power, so they may find it harder
                       to share.
                        "Public participation." as usually practiced, is not a
                       satisfactory substitute for power-sharing. To be sure, telling
                       the public what you're doing is better than not telling the
                       public what  you're doing. Seeking "input" and "feedback" is
                       batter stilL But most public, participation is* too. little toolate?
                       "After yean of effort, sumnarizat) in thi» 30&-pege> report, we
                       have reached the following conclusions.... Now what do you
                       folks think?" At this point it is hard enough for the agency to
                       take the input seriously, and harder still for the public to
                       believe it will be taken seriously. There is little power-
                       sharing in  the "decide-announce-defend" tradition of public
                        The solution Is  obvious, though difficult to implement.
                       Consultations with the public on risk management should
                       begin early fat the. process and continue !*"""g*"«'* This
                       means an agency must be willing to tell the public about a
                       risk be/ore it has done its homework—before the experts
                       haw assessed the risk thoroughly, before all the policy
                       options have been articulated, way before the policy
                       decisions have been made. There are dangers to this strategy:
                       people will ask the agency what it proposes to do about the
                       problem, and the agency will have to say it isn't sure yet. But
                       on balance an agency is better off explaining why it doesn't
                       yet have all the answers than explaining why it didn't share
                       them yean ago. In fact, not having all the answers can be
                       nude into  an asset, a demonstration of real openness to
                       public input The goal, after all, is to enlist the rationality of
                       the citizenry, so that citizen* and experts an working
                       tofrtfaer to fignr*our, bow greet thv nsk is end what to- do
                       •bout it
-c.pl.;.;.., Eavmuneaai Ri»fc SOB* Now* oo Environmental Risk Conmunic«im.*  by Peur M. Sudmu for the TSCA
Office, Office of Tone Submancei. U.S. Envooameaul Praecuoa Agency, November 1986.

                        Of course no responsible agency will go public without
                      any answers. What's important is to propose options X. Y,
                      and Z tentatively, with genuine openness to V and W. and to
                      community comments that may eliminate Z. A list of options
                      and alternatives  and »fair and open procedure for
                      comparing them and adding new ones—is far more
                      conducive to real power-sharing than a "draft" decision.
                        This sort of genuine public participation is the moral right
                      of the citizenry. It is also sound policy. Undeterred by
                      conventional wisdom, lay people often have good ideas that
                      experts can adapt to the situation at hand; at a minimum.
                      lay people ore the experts on what frightens them and what
                      would reassure them. When citizens participate in a risk
                      management decision, moreover, they are far more likely to
                      accept it, for at least three reasons: (1) They have instituted
                      changes that make it objectively more acceptable: (Z) They
                      have got past the process issue of control and mastered the
                      technical data on risk; that is, they have learned why the
                      experts consider it acceptable; and (3) They have been heard
                      and not excluded, and so can appreciate the legitimacy of the
                      decision even if they continue to dislike the decision itself.

                       6. Explaining risk information b difficult but not
                      impossible, if the motivation is there. High school teachers
                      have long marveled that a student who couldn't make sense
                      of Dickens'* A Tale of Two Citie* had no trouble with Hot
                      Jtotfr far mow txnnpleji UisUuctiuiu on bow to adjust one's
                       sparkplugs for a fast start on a rainy day. Motivation makes
                       the difference. When people have a reason to learn, they
                         It is still possible for communicators to make the learning
                       easier or harder—and scientists and bureaucrats have
                       acquired a fairly consistent reputation for making it harder.
                       At Three Mile Island, for example, the level of technical
                       jargon was actually higher when the experts were talking to
                       the public and the news media than when they were talking
                       to each other. The transcripts of urgent telephone
                       conversations between nuclear engineers were usually
                       simpler to understand than the transcripts of news
                       conferences. To be sure, (argon is a genuine tool of
                       professional communication, conveying meaning (to those
                       with the requisite training) precisely and concisely. But it
                       also serves as a tool to avoid communication with outsiders.
                       and as a sort of membership badge, a sign of the status
                       difference between the professional and everyone else.
                         Like any piece of professional socialization, the tendency
                       to mystify outsiders becomes automatic, habitual more than
                       malevolent It's hard for a  layperson to get a straight answer
                                    t •van whan nothing, much te at stake. Whan-a
                       potentially t*riou»iisfc is at stake.
"EtpUiniof Eovirewneaul Riifc Some Notes M Eaviraomeaul Ri«k Gxnmuciuan.* by Ptur M. Simtmin far the TSCA Auiiuoce
Office. Office of Toxic Substances. U.S. EavirraiDeaul Pmcctioi Agency. November 1986.

                      frightened or angry or exhausted, when the experts aren't
                      sure what the answers are, when the search for a scapegoat is
                      at hwi. effective **v™i*n"t*^»*'*m ig a lot (Q expect.
                        Itt mny risk «^»»«m^iriifatinfi interactions, in short, the
                      public doesn't really want to understand (because it feels
                      powerless and resentful) and the experts don't really want to
                      be understood (because they prefer to hold onto their
                      information monopoly). The public finds it convenient to
                      blame the experts for obfuscation, and the experts find it
                      convenient to blame the public for obtuseness. These
                      motivational issues are probably more important than  the
                      traditional concerns of clarity in determining whether re.al
                      knowledge will pass from expert to public.
                        Within the traditional concerns of clarity, the major issue
                      is simplification. Even assuming a public that wants to
                      nnHnfjrtflnd iptj an expert who wants, to he undcislood. risk
                      information must still be simplified.
                        Insofar as possible, of course, it is wise to simplify
                      language rather than content. That is, take the extra words to
                      make hard ideas clear. Unfortunately, neither the expert
                      source nor the lay audience is usually willing to dedicate the
                      time needed to convey complex information a step at a time.
                      So inevitably simplification becomes a matter of deciding
                      what information to leave out. Experts are famous for their
                      COOVK.UUII that no infonnatkm may be- toft out; unable to tell
                      ail* they often wind op tetUing nothing:
                        In fact, there are three standard rules of thumb for
                      popularizing technical content, (t) Tell people what you
                      have determined they ought to know—the answers to the
                      questions they are asking, the instructions for coping with
                      the crisis, whatever. This requires thinking through your
                      information goals and your audience's information needs,
                      then resolutely keeping the stress where you have decided it
                      should be. (2) Add what people roust know in order to
                      tmdentand and /ed that they understand the information—
                      whatever context or background is needed to
                      prevent confusion or misunderstanding. The key here is to
                      imagine where the audience is likely to  go off-track, then
                      provide the Information that will prevent the error. (3) Add
                      enough qualifiers and structural guidelines to prepare people
                      for what you are not telling them, so additional information
                      later will not leave them feeling unprepared or misled. Partly
                      this is just a matter of sounding tentative; partly it is
                      constructing a scaffolding of basic points on which people
                      can hang the new details as they come in. Applying these
                      three rules isn't easy, but it  is a lot easier than trying to tell
                      everything you know.
                        The. hardest put of simplifying, risk information is explain-
                      ing the risk itself. This as hard not only because risk,
'Explaining Environment*! Riifc Some Note* oo Environment*] Risk Conumntcaiioa.* by Peter M. Sudaun for the TSCA Aisuuace
Office. Office of Toxic Subnuce*. VS. Eavtroamenul Protection Agency. November 1986.

                       raents are intrinsically complex and uncertain, but also
                       because audiences cling tenaciously to their safe-or*
                       dangerous dichotomy. One path out of dichotqmous
                       thinking is the tradeoff: especially risk benefit, but also
                       risk-cost as risk-risk. But there i& solid evidence that
                       lay people resist this way of thinking; trading risks against
                       benefits is especially offensive when the risks raise moral
                       issues and the "victims" are not the ones making the choice.
                       Another alternative to dichotomy  is the risk comparison: X is
                       more dangerous than Y and less dangerous than Z. But as we
                       have already noted, risk means a lot more than mortality
                       statistics, and comparing an involuntary risk like nuclear
                       power to a voluntary one like smoking invariably irritates
                       more than it enlightens — as does ony risk comparison that
                       ignores the distinctions listed at the start of this section.
                         The fi"*i option to dichotomy is to provide, tivt m*^ifl data
                       on deaths or illnesses or probability of occurrence or
                       whatever. This must be done carefully, with explicit .
                       acknowledgement of uncertainty, of moral issues, and of
                       non-statistical factors like voluntariness that profoundly
                       affect our sense of risk. Graphs and charts will help; people
                       understand pictorial representations of probability far better
                       than quantitative ones.
                         Don't expect too much. People can understand risk
                       tradeoffs, risk comparisons, and risk probabilities when they
                       an carefully explained. But usually people don't really want
                       to undeataod- Those who are frightened, angry, and
                       powerless will resist the information that their risk is
                       modest; those who are optimistic and  overconfident will
                       resist the information that their risk is substantial. Over the
                       long haul, risk communication has more to do with fear,
                       anger, powerlessness. optimism and overconfidence than
                       with finding ways to simplify complex information.
                       7. Bi«ir ^frimimiit*»atimi is aasier when emotions are seen aa
                       legitimate. It follows from what we have been saying that an
                       iinpuitaiU aspect of risk communication is finding ways to
                       address the feelings of the audience. Unfortunately, experts
                       and bureaucrats find this difficult to do. Many have spent
                       yean learning to ignore feelings, their own and everyone
                       else's: whether they are scientists interpreting data or
                       managers setting policy, they are deeply committed to doing
                       their jobs without emotion.
                         At an even deeper level, scientists and bureaucrats have
                       had to learn to ignore the individual, to recognize that good
                       science and good policy must deal in averages and
                       probabilities. This becomes most obvious when a few people
                       feel threatened by a generally desirable action, such as the
                       siting of a hazardous waste facility. Experts who are
                                that ***< risk is im^U «n^ tj*» facility neadad. may
'Explaining Eavmoraul Rkfc Son* Noa 
                       well try.to sympathize with the target community—but their
                       training tells them playing the odds is a good bet. somebody
                       has. to tak& the risk, the ^yitiQ" is rational  anj that's the
                       end of thi* *nfl**Br
                         Thus the most common sources of risk information are
                       people who are professionally inclined to ignore feelings.
                       And how do people respond when their feelings are ignored?
                       They escalate—yell  louder, cry harder, listen less—which in
                       turn stiffens the experts, which further provokes the
                       audience. The inevitable result is the classic drama of
                       stereotypes in conflict: the cold scientist or bureaucrat versus
                       the hysterical citizen.
                         Breaking this self-defeating cycle is mostly a matter'of
                       explicitly acknowledging the feeling (and  the legitimacy of
                       the fading) before trying to explain anything substantive—
                              ' any effort to explain substance fic&t will
                       be experienced by people as just another way of not noticing
                       how they feel. The trick, in other words, is to separate the
                       feeling from the substance, and respond to the feeling first. "1
                       can tell you're angry about this" won't eliminate the anger—
                       nor should it—but it will eliminate the need to insist
                       on the anger, and will thus free energy to focus on the issue
                       instead. "A lot of people would be angry about this" and "in
                       your position 1 would be angry about this" are even more
                       empathic remarks, legitimating the anger without labeling the
                       cjfigfffi. AH three responses are fanmnre txseftti ft*»*?
                       pretending that the anger isn't there or, worse yet.
                       demanding that it disappear. Techniques of this sort are
                       standard practice in many  professional contexts, from police
                       crisis intervention to family counseling. Training is available;
                       risk communicators need not reinvent the wheel.
                         It helps to realize that experts and bureaucrats—their
                       preferences notwithstanding—have feelings too. In a public
                       controversy over risk, they are likely to have very strong
                       feeling* indeed. After all. they consider themselves moral
                       people, yet they may be accused of "selling out" community
                       health or safety or environmental protection. They consider
                       themselves competent professionals, yet they may be accused
                       of egregious technical errors. They very likely pride
                       themselves on putting science or public service ahead of
                       personal ambition, yet they may be accused of not caring.
                       They chose their careers expecting if not gratitude at least a
                       calm working environment and the trust and respect of the
                       community. Instead they are at the center of a maelstrom of
                       community distrust, perhaps even community hatred. It
'Explaining EnvBoomenul Risk:
Office, Office of Toxic Sutxuno
 Some Not*» at Eavirenneaul Risk Comnnmicttioo.' by Pacr M. *""»•»"» for (he TSCA ASIISUIKC
3, US. Eavirauneaul Pixxeaioo Agency. November 1986,

                         The pain can easily transform into a kind of icy paternal-
                       ism, an 'Tnvgoing-to-help-you-even-if-you-don't-know-w hat's-
                       good-for-you" attitude. This of course triggers even more
                       distrust, even stronger displays of anger and fear. Risk
                       communication stands a better chance of working when both
                       sets of feelings—the expert's and the community's—are on
                       the table.
                         Feelings are not usually the core issue in risk communica-
                       tion controversies. The core issue is usually control, and the
                       way contra! affects how people define risk and how they
                       approach information about risk. But the stereotypical
                       conflict between the icy expert  and the hysterical citizen is
                       nonetheless emblematic of the overall problem. The expert
                       has most of the "rational" resources—expertise, of course;
                       stature; fai-mat control of 'k** 'tltinvrit** 'k^^iTi Neither a
                       direct beneficiary nor a potential victim, the expert can
                       afford to assess the situation coldly. Indeed, the expert dare
                       not assess the situation in any other way. The concerned
                       citizen, meanwhile, has mainly the resources of passion—
                       genuine outrage; depth of commitment; willingness
                       to endure personal sacrifice; community solidarity; informal
                       political power. To generate the energy needed to stop the
                       technical juggernaut, the citizen must assess the situation
                         A fundamental premise of "Explaining Environmental
                       Risk" is that risk understanding and risk (incision-making
                       will improve when control is democratized. We will know
                       this is happening when citizens begin approaching risk
                       issues more coolly, and experts more  warmly.
'ExpUining Environmental Risk: Some Notei on Eaviroomcaul Rjik Communication." by Peter M. Sandman for the TSCA
Office. Office of Toxic Subsuncei. U.S. Environmental Protection Agency. November 19S6.

                      Selected  Bibliography
                        Covello, Vincent T.. "The Perception of Technological
                      Risks: A Literature Review," Technological Forecasting and
                      Social Change, 1983. pp. 285-287.

                        Covello. Vincent T., Oetlof von Winterfeldt. end Paul
                      Slovic. "Communicating Scientific Information about "Health
                      and Environmental Risks: Problems and Opportunities from a
                      Social and Behavioral Perspective," in V. Covello. A.
                      Moghissi. and V.R.R. Uppuluri, Uncertainties in Risk
                      Assessment and Risk Management  (New York: Plenum
                      Press. 1966), in press.

                        Fischhoff, Baruch. "Protocols for Environmental Reporting:
                      What to Ask the Experts." The Journalist (Foundation for
                      American Comnmnications). Winter 1965, pp. 11-15.

                        Klaidman, Stephen, "Health Risk Reporting," Institute for
                      Health Policy Analysis. Georgetown University Medical
                      Center. Washington, DC. 1985.

                        Mazur. Allan. "Media Coverage and Public Opinion on
                      Scientific Controversies, Journal of Communication. 1981.
                      pp. 106-115.

                        MazQi, Allan. "Bias in Risk-Benefit Analysis." Technology
                      in Society, 1985, pp. 25-30.

                        Nelkin. Dorothy, Science in the Streets (New York:
                      Twentieth Century Fund, 1984).

                        President* Comnnsston on the Accident at TnTee*Mile
                      Island, Report of the Public's Right to Information Task Force
                      (Washington, DC: U.S. Government Printing Office, 1979).

                        Ruckelshaus, William. "Risk in a Free Society." Risk
                      Analysis, September 1964, pp. 157-163.

                        Sandman. Peter M., "Getting to Maybe: Some
                      Communications Aspects of Hazardous Waste Facility
                      Siting." Seton HoJl Legislative JoumaJ. Spring 1986.
*E«pUiiuDg Environmental Riifc Some Kola oa EaviraomeBUl Ruk ComnmnicMoo.'  by Pea M. Sudmu far the TSCA Asiiiuacr
Office. Office of Toxic Sufartucei, VS. EDviroameiiul PmeoUoa A|eoey. November 1986.

                        Sandman. Peter M., David B. Sachsman, Michael
                      Greenberg, Mayme jurkat. Audrey R. Gotsch, and Michael
                      Gochfeid, "Environmental Risk Reporting in New Jersey
                      Newspapers." Environmental Risk Reporting Project.
                      Department of Journalism and Mass Media, Rutgers
                      University, January 1986.

                        Sharlin, Harold I.. "EDB: A Case Study in the
                      Communication of Health Risk." Office of Policy Analysis,
                      U.S. Environmental Protection Agency. January 1985.
                        Slovic, Paul, "Informing and Educating the Public About
                            Qecuion Research Report 85-S. November 1984.
                        Slavic, Paul. Baruch Fischhoff. and Sarah Lichtenstein.
                      "Facts and Fears: Understanding Perceived Risk." in R.C.
                      Schwing and W. Al Albers. eds.. Societal Risk Assessment:
                      How Safe is Sa/e Enough? (New York: Plenum. 1980). pp.
                        Weinstein. Neil D., and Peter M. Sandman.
                      -Recommendations for a Radon Risk Comirmniratk
                                Office? of Science1 arur Revevcn, New Jersey
                                 of Environmental Protection. November 1985.
"Explaining Environmental Riifc Some Notes OB Environmental Risk Communication." by Pas M. StndniM to th« TSCA
Office, Office of Toiic Subiuocci. U^. Environmental Proteeuoo Agency. November 1986.


                         PUBLIC MEETING


                              Prepared by

     CDR Alvin Qran, USPHS, Senior Environmental Health Policy Advisor
                   Arnold R. Den, Senior Science Advisor
                   Office of the Regional Administrator v
              U.S. Environmental Protection Agency, Region 9
      Following is a list of questions which axe often asked by the public,
along with some typical responses. The list is taken from EPA, Region 9's
Risk & Decision Making and Risk Communication & Public Involvement
Courses.  It serves to illustrate the use of EPA's Seven Cardinal Rules of Risk
Communication and the careful preparation that is required.

      The authors welcome your comments and any suggestions for
additional questions. Based on your responses, the list may be expanded or
revised. All comments may be directed to the authors at (415) 744-1019 or
      A CAUTION TO THE READER - The sample responses are offered
      only as ideas, from which you must develop your own responses.
      The responses are not intended to be memorized and used
      verbatim. A response may be used only if it addresses the
      specific needs of your audience, and it is comfortable for both you
      and your agency. Your responses must be open, honest, frank,
      and meet the needs of your public or audience. It may not be
      obvious, but developing your responses usually requires policy
      input from management as well as technical input from other
      credible sources.  This preparation is essential to your performance;
      if you fail to prepare, you cant expect to gain the important trust
      and respect of our public constituents, and you wont be effective.

    Seven Cardinal Rules  of  Risk Communication
        1. Accept and involve the public as a legitimate partner.
        2. Flan carefully and, evaluate your performance. (CR2?
        3. Listen to the public's feelings. (CR3)

           (Examples of "active listening* are offered in some of the
           responses to the questions which follow.  These specific
           examples are underlined for easy reading.)

        4. Be honest, open, and frank. (CR4)
        5. Coordinate and collaborate with other credible sources.
        6. Meet the needs of the media. (CR6)
        7. Speak dearly and with compassion. (CRT)
'Public Meeting: Typical Questions and Sample Responses.* By Alvin Chun ind Arnold R, Den, Office of the Regional
Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

      1.     Q.    Why can't I ask my question now?

            Underlying Public Need:  The Agency agenda isn't working and the
            public would  like their concerns and questions addressed first.
      •  Reminder Noter Underlined sentences are. CXSIFPlcS of "activg ||gtening."

            A.    Sounds like ther<» are a lot of questions that need to be answered
                  now. Maybe we should do that first and save the rest of the
                  agenda for later? Is that OK? (Principles: Listen, feedback, and
                  accept the public as a legitimate partner in deciding on the
                  agenda.)  (CR1,3)

            A.    I know vou all have a lot of questions that you want answered.
                  Would it be alright if we proceed with the 20-30 minute
                  presentation, where I suspect that many of your questions will be
                  answered, and then leave the next period of time for the rest of
                  your questions? (Principles; ti?***", femHhark with a
                  recommendation and accept the public as a legitimate  partner in
                  deciding on the agenda.) (CR 1, 3)

            A.    Poor Response: Please let me finish my talk!  (Not listening to
                  the audience's need for answers to their questions, and giving
                  the impression that we don't care and that we know better than
                  they do.  Thus, we are not treating them as legitimate partners.)

            A.    Poor Response  Please tenth hand raised at audience) all
                  questions will be taken after our presentation! We need to
                  follow the agenda. Let us give our presentation and then we'll
                  take questions.

     2.     Q.    Why won't you answer my question? (This is usually a follow-
                  up question to Question #1 when the Agency insists that
                  questions will be answered only after the presentation,)

            Underlying Public Need:  The public would like to  vent feelings  and
            have us listen and be responsive  so that  they can find out if we are on
            their side and taking adequate action*.  Also, they may not want a
            "slick" presentation but are  more interested in direct answers to  their
            personal  questions.

            A.    I apologize if we have not answered vour Questions. I have
                  written vour questions here (on flip chart), and I have saved this
                  part pf the agenda to answer them.  I think that many of your
                  questions will be answered in the 20-30 minute presentation that
                  we have prepared, and it may save everyone some time. Our
"Public Meeting: Typical Questions and Sample Responses/ By AJvia Chug and Anotd R. Den. Office of the Regional Administrator.
Office of the Senior Science Advisor. EPA Regies 9. revised January 1992.

 presentation will cover some important questions which may be
~on your mind such as, "Is my family safe?  What are we
 planning on doing about it? What's been going on?"  If that
 sounds like it will work for you, could we proceed? And if it
 isn't working, then we'll have to think of something else.
 (Principles: Listen, feedback with helpful suggestions and
 involve the public in deciding how to proceed.)  (CR 1/3)

 You've asked a very good question and maybe we haven't been
 listening tflo wej^- How many of you have questions  itrd would
 like them answered? I see mere are a lot of questions. Let me
 make 2 suggestions for how you might want to proceed, and you
 can tell me if either one sounds good.  (Principles:  Listen,
 feedback with helpful suggestions and involve the public in
 deciding how to proceed) (CR1,3)

 One suggestion is to answer your questions first until they are
 all answered, and then if you are still interested and have the
 time, we could give our 20 minute presentation. Also, we have
 a fact sheet which. «"Trrf>a"'*a< much of the presentation if you
 can't stay for the whole meeting.

 The other suggestion is to let us give a 20-minute presentation
 so that everyone will have some common  understanding of the
 situation, and be able to ask some questions which they may not
 have otherwise. We have a 20 minute presentation, and it may
 answer many of your questions. After the presentation, we can
 spend the rest of the evening answering aQ your questions.
 Since there are a lot of questions, and many of you can't stay pass
 11 P.M., when the meeting was suppose to end, we will try to
 accommodate your questions first and stay until all your
 questions have been addressed.

 Now lef s have a show of hands to decide how we should
 proceed. How many would like to hear the presentation first?
 How many would like  to get at the questions first?

 Poor Response:  Sir, if you would just let me finish, HI get to
 your question at the end, and we'll answer all questions then.
 (Not listening to the public; Agency is more concerned about
 sticking to the agenda and maintaining control of the meeting.
 In its attempt to maintain control, the Agency will likely lose
 control. An important  point to consider: If your meeting goal is
 to give your presentation at any expense, then mis would have
        goat Oar goal normally is to try to meet the needs of the

•Pdblie Meetuif: Typical Qoejtioa* mi Sanpfc Retpmses." By Alvio Onin and Areotd R. Da, Office of the Regional Administrator
Office of die Senior Sdeace Adviior, EPA Refioa 9, revised January 1992.

             community in trying to solve the environmental problem.
             Given that as our goal, if a community is insisting to be heard
             we should recognize their need and try to meet it, or present
             them with alternatives that meet both their needs and the
             Agency's, and let them choose.)

 3.     Q.    What have you done about it? Why are you taking so long?

       Underlying Public Need:  The public would like to know if we are
       being responsive in correcting the problem,, end if we care.

       A.    Sir, you'd like to know what we're doing, and you're anyrv that
             it's taken so long. We share your concerned about taking care of
             this  as quickly as possible.  Unfortunately, there are no simple
             solutions for cleaning up hazardous waste sites.  Each site must
             be carefully characterized before a dean up plan can be made to
             enable us to do a good job. This takes longer than we would all
             like  but it is needed to ensure that it is done right in order to
             safeguard public health. We are proceeding as fast as we can, and
             here's what we are doing:	„  (Principles: Listen, feedback,
             share concern, and answer.) (CR 3,4,7)

      A.    Poor Response:  Ah, Ah, Ah.....Don't you know we're doing our
            best! (Didn't have an answer, wasn't prepared to answer a basic
             question, and became defensive. This increases the public
            outrage which delays discussion on options and solutions.)

      A.   Poor Response: r have 5 other sites that Fm working on and Tm
            working hard on all of them. (The public is not interested in
            other sites or excuses.  They want to know what we are doing
            about their site to protect them.)

4.     Q.    Why haven't you dosed the plant? How many more cancers do
            you  want?

      Underlying Public Need:  The public  is worried about cancer (or same
      other health issue) and needs to know  how we're planning  on
      addressing the problem and if we care about them.  To the public,
      closing the  plant is  a logical solution.

      A.    We share vour concerns about health. Let us assure you that the
            plant isn't posing an immediate health hazard where dosing the
            plant would be needed. However, a long term and constant
            exposure to DNC could present a health hazard, and that is why
            WE are proposing 901110 iinznediite. actions which will ensure
            your safety. Here's what we are proposing and we believe this

 "Public Mectiag: Typical Questions ind Simple Retpoasei." By Alvia OHIO aad Arnold R. Deo. Office of the Regional Adminuuaiot
 Office of the Senior Science Advisor. EPA Region 9, revised Juuiry 1992.

            will correct the problem, protect your health, and not create a
            hardship for the people who are currently employed at the plant.
            (Principles: Give a direct answer that addresses our concern for
            protecting people's health and welfare, and state our actions.)

      A.    Poor Response:  Let me finish my presentation!

      A.    Poor Response:  We've been working with the plant, and we
            don't think that it's necessary!

5.    Q,    Is it safe? Are my kids cafe?

      Underlying Public Need:  The public needs to know if there is any
      immediate danger to their family and that we care about that.  They
      want "micro" risk answers to the "Am I safe?" questions,  not "macro"
      risk answers which the Agency has been concerned with in their
      decision making. U., "The hazard presents a.  IQ~5 risk to the.
      community. *

      A.    Your concern for safety is our concern also.  Any cancer causing
            agent is potentially dangerous (The non-threshold concept).
            DNC is such a substance. Based on our knowledge of the
            amount of DNC that people are being exposed to, we feel it is
            safe for all residents east of Bectrobotics because DNC isn't in the
            air or drinking water.  For residents to the west of Electrobotics,
            DNC is only present in the air, but in such small quantities that
            exposure will only be  a health concern if it is not reduced in the
            next several yean. We are proposing  to reduce and minimize
            the exposures to DNC by permanently capping the source of the
            DNC to eliminate its presence in the air, and cleaning up the
            contaminated soil to minimize any contamination  of the water.
            This will make it safe. (CR 3,4)

            For a more typical case when the contamination ctamot  be
            totally removed from the ground water, a response could be:

      A.    Your concern for safety is our concern also.  Any cancer-causing
            agent is potentially dangerous (The non-threshold concept).
            DNC is such a substance. Based on our knowledge of the
            amount of DNC  which people are being exposed to, we feel it is
            safe for all residents east of Bectrobotics because it  isn't in the air
            or drinking water.  For residents to the west of Bectrobotics,
            DNC is only present in the air, buLuvsuch nr^ll miapririac that
            exposure wffl only be a health concent if it is not reduced in the
            next several years. We are proposing immediate actions to

•Public Meeting: Typical Questions tad Staple Responses.' By Alvin Own tad Anold R. Den. Office at the Regional Administrator
Office of (he Senior Science Advisor. EPA Region 9. revised Jtmafy 1992.

           reduce and minimize the exposures to DNC by permanently
           capping the source of the DNC to eliminate its presence in the
           air, and cleaning up the contaminated soil to a safe level. (In this
           case there will be a  finite but small concentration of DNC
           remaining in the drinking water, but it will be at a level which is
           between 10~4 to 10~6 risk which we, as Agency personnel, have
           established in the regulatory processes for various  air, and water
           standards as being "safe." This still may not be acceptable to
           some people, and understandably so, especially if they hadn't
           been involved in the decision making process. Similarly, it may
           not be acceptable to you as an Agency person because the risk is
           not zero, and a residual risk remains.)  (CR 3,4)

     A.    Your concern for safety is our concern also. We believe it is safe
           for you and your kids to drink the water and breath the air.
           There is no DNC in the drinking water, but we feel there will be
           in the future if a leak from  the company's holding pond is not
           controlled.  There is some DNC contamination in the air and
           this will become a dangerous situation if it is not controlled and
           people are exposed to it over their entire life.. (CR 3,4)

     A.    Poor Response: The life time risk of getting cancer based on the
           current level of DNC in the air is 1(H. Based on that estimate,
           we feel that we should  reduce the risk to a level of 10^. (What's
           probably not needed here is more jargon.)

•     Q,    Art lime any cxfv levefe for 2 carcinogen? (Class* A, B, or C

     A.    Your question on carcinogens is an excellent one. EPA has
           identified some chemicals as (A) known, (B) probable or (C)
           possible human carcinogens based primarily on human data (A),
           and on animal studies (B and Q.  If we believe it to be a
           carcinogen, we assume that all levels of exposure wiH have
           some level of cancer risk. The smaller the exposure, the smaller
           the risk. We generally describe these risks in terms of
           probability.  If in asking your question, you want to know if there
           are levels of exposure that are free from risk, the answer is no.
           If, on the other hand, you are asking whether certain levels of
           chemical exposure are too small to be of a health concern, then
           the answer is yes.  Our goal is to reduce the level of exposure to a
           safe level where it will be safe to drink the water and breath the
           air. (Remember that a safe level does not necessarily mean zero
           risk. It could T^arr far ***^inTtfc tbifr Ift^ or 10"^ risk is a safe
           level. There are ouiiy reasons why zero risk may not be feasible,

 "Public Meeiia|: Typical Question* and Sample Responses." By AJvia Chun aod Arnold R. Den. Office of the Region*!
 Office of the Senior Science Advisor, EPA Region 9. revised January 1992.

            but one must also remember that 1(H or 10-5 are upperbound or
            maximum risks. This means that the actual probability may be
            much lower and may even be zero because of all the health
            protective assumptions that are used.) (CR 3,4)

7.    Q.    Would you drink our water? What about breathing our air?

      Underlying Public  Need: Again, the  public would like to know how
      this affects their family and if we ore, sincere about our concern for

      A.  .  Yes, I would drink the water because it is not contaminated, and
            I am here breathing the air because it is such a low risk that it
            isn't a health problem.  I understand that some of you may feel
            that any concentration of PNC in the air is unsafe. If you feel
            that way, I would recommend that you consult with your doctor
            or do what you feel will make you more comfortable. However,
            we feel ttvflrc is **** immediate HiT"**^ ay"^ we ***** Hgan ^m the
            situation so that there will be no long term health concern. (If
            there was an immediate health hazard, an emergency response
            action would be ordered, and bottled water could be offered or
            recommended if the drinking water was  contaminated.)

      A.    Poor Response: That's a personal choice whether to drink the
            water or not

      A.    Poor Response (Hesitates and doesn't answer.)

8.    Q.    How can you say ifs acceptable? My family has cancer! Look at
            the neighborhood and all the sickness and cancers!

      Underlying Public Need: Public  wants to have  some control over
      determining what is acceptable, and to have  it be as safe as possible*

            (The phrase "acceptable risk" should not be used because it
            requires a value judgement which can only be made by the
            public, not solely by an agency. An agency can decide what it
            considers "safe" and the public has every right to say that it isn't
           Fm hearing that you're not satisfied with our clean-up proposal.
           and that you're very concerned about the cancer which the
           contamination wyv cause  We> too- are concerxiedp and that is
           why the ctean-up plan that we* are? proposing address
           concern for safety. The plan will clean up die contamination to

"Public Meeting: Typical Questions and Sample Responses," By AJvlo Chan and Anoid R. Den. Office of the Regional Adminuinicr
             a safe level.  However, it sounds like you might be more
             comfortable with a greater-than-safe level which we are
             proposing. I can't make any promises, but I would be interested
             in any ideas or concerns which you may have.  But at this time, I
             am confident that our proposal will make it safe for you and
             provide the level of health protection which you are expecting.

       A.    It's unfortunate that there is so much  sickness. I am concerned
             and sad to hear that Our goal is to make it as safe as possible
             with your input I believe we can develop  a solution,to control
             therisk. (CR3,4,7)

       A.    Poor Response  If s acceptable because the risk is IO-*.  Based on
             that risk level, we don't see how those illnesses and cancers can
             be attributed to DNC

       A.    Poor Response  We don't know what caused the cancers.
             However, you should  know that 1 out of 4 of you win get cancer
             in your lifetime because of everyday activities and exposures.
             For example, it's more likely that you'll  get cancer from eating
             peanut butter or charcoal broiled steaks  than it would be from
             exposure to DNC.  (Whether this is true or not is irrelevant
             when people are upset. The people want to be involved.
             They are not asking for an explanation.  In this case, an
             explanation belittles the public and their concerns over the site.)

9.     Q,    What does IX10 •* mean? What is risk?

       Underlying Public Need:   The public  needs to know if we're trying to
       "snow them" with jargon or  if  we're  looking  after  their best interest.
       Discussing first how the situation affects them personally, i*., "Is  it
       safe?" will reach people directly and get at their needs.  Then, the public
       may  want to have specific technical discussions about risk calculations.
       Often, if the agency has done a good job addressing the "Is it safe?"
       question with  honesty  and compassion,  the agency will  have
       established some level of  trust and credibility where the public will  be
       witting to focus on the 1Q~6 terminology.  Surprisingly, if the  agency
       has done its  job well in establishing trust  and credibility with the
       public,  the public's  need  to know about  10~&  will not be needed!  Often
       times agencies tend  to focus on the 10~* issues too soon  with  the public
       without  adequately addressing the  real public concerns.  This then
       creates a diversion  to argue about  1Q~& and misleads the  agency to
       think that if only they could have explained 10"6 better, it would  haze
       not created on argument  with the public.   The  argument  was probably

'Public Meeting: Typical Questions and Sample Responses.* By Alvin Oiun and Arnold R. Oca. Office of the Regional Adminutraor
Office of the Senior Science Advisor. EPA Region 9, revised January 1992.

      over the agency not listening, and as M result some underlying public
      needs were probably not met.

            Assuming that this question is being asked at a technical
            meeting, some answers could be:

      A.   Risk is the probability or chance of getting cancer. 1x10"^ is
            another way of saying one-in-a-million chance of getting cancer
            (above the "f*"*18! -t>afVgrotiTi'fl- r^n^r?V In. our d?fJT"*''nnj OJM~
            in-a-million is a probability based on data and many health
            protective assumptions that there may be one extra cancer case
            in a population of 1 million people over a lifetime of exposure
            to a chemical.  The probability is an upperbound estimate and
            can be thought of as a maximum probability because worst case
            situations are assumed where science has no definite answers in
            order to be on the safe side of protecting public health.  For
            example, "How is cancer caused?" is still an unanswered
            scientific question.  To make up for this uncertainty, and since it
            is difficult to study human subjects over their lifetime, we rely
            on animal studies to determine the cardnogenicity of most
            chemicals.  Because the one-in-a-million probability is  an
            upperbound or maximum probability it means  that a cancer case
            may not occur at all, but if it does, there is at most a one-in-a-
            million likelihood for an extra cancer case above the expected
            250,000 cancer cases that would normally occur in a population
            of 1 million.' (Remember, in the absence of sufficient data.
            worst case ana trpperbound assumptions are used in ore risk
            assessment This means that calculated risks are probably orders
            of magnitude higher than they  should be, but since we don't
            have definite data and we are dealing with carcinogens, we want
            to be protective of public health and safety.) (CR3,4)

      A.   In this situation, we are talking about cancer risk. Cancer risk is
            the likelihood or chance of getting cancer.  When we write,
            "1 x 10"*" or say "one times ten to the minus sixth," we are using
            scientific terms to say "one-in-a-million." If we were to say there
            is a one-in-a-million excess cancer risk from a given level of
            exposure to a chemical, we mean that each individual exposed to
            that chemical at that level over his/her lifetime has a one-in-a-
            million chance of getting cancer from that particular exposure.
            This is similar to saying that because of mat chemical we could
            expect to see one additional cancer case in a population of one
            million people who are all exposed under the same
            QXQQSt9fc2ZlGGS* HOWCW^ZV %VC Sfty CXOBS& CUKGGf T1SK  Afifiv.-
            "additional cancer" because we  already expect to see, due to aH

"Public Meeting: Typical Questions and Sample Responses.* By Alvia Chun and Arnold R. Den. Office of the Regional Adnuomraui
Office of the Senior Science Advisor, EPA Region 9. revised January 1992.

               other causes, about 250,000 cancer cases in a population of one
               million people.

               You should also realize, however, that there is a great deal of
               uncertainty that accompanies our risk estimates. Science has not
               yet progressed far enough to explain exactly how cancer is
               caused. Nor can we ever be absolutely sure of the levels of a
               chemical that are present in the environment But in order to be
               protective of public health, our risk assessments are designed to
               account for the various uncertainties.  In fact* where our
               information is incomplete, we use assumptions that tend to
               overestimate the risk in order to further insure that we are being
               health protective. As a result, when we estimate that there is a
               one-in-a-million risk, the actual risk has very little chance of
               exceeding one-in-a-million. In actuality, one-in-a-million most
               likely overestimates the actual risk, and, in fact, may be zero.

               Assuming that this question is being asked at a non-technical
               public meeting some answers could bet
         A.    IX 10*6 is an expression which scientists often use to express one
               chance in a million.  This in risk terms means one chance in a
               million of getting cancer from being constantly exposed to a
               certain level of a chemical over one's lifetime of 70 years. If that
               still isn't a  good enough explanation, let me explain it another
               way and hopefully, this will be more helpful: DNC is a
               dangerous chemical btxausp we have reasons to believe that it
               may cause cancer. Currently, there is no danger to you if you
               drink the water because it isn't contaminated. The air is
               contaminated with DNC, but in such small levels that it is safe
               in the short-term provided we further reduce the  contamination
               to a lower level where it will be also safe in the long-term. I'm
               sorry if this sounded confusing because on the one hand we're
               saying it's safe in the short term, but on the other hand we're
               proposing to clean it up which  will make it safe in the long term.
               If this is still confusing, let me use an analogy which may make
               this a little  clearer. Some of you may say that my example is
               ridiculous because it will never happen, and you're right, but for
               a lack of a better example, allow me to try this one just to see if it
               gives you at least a better feel for what we have been talking

               Imagine that there's a pallet of cement weighing 900 Ibs
               suspended over your house The pallet is being held by a cable
               which is rated at 1000 Ibs.  Yon axe sale because the cable hasn't
               snapped and it isn't likely to.  You may feel safe for a long time

•Public Meeting: Typical Qnemoai ud Safapfe tejpmucs.* By AJvia Chun ud Arnold R. Dea. Office of the Regional Adnuoiflrux
Office of the Senior Science Advisor. EPA Region 9. revised J«nu«ry 1992.

            if the pallet remains overhead because the cable can probably
            support 2000 Ibs. There is usually a safety factor built into
            the strength rating; however, you and your family may feel very
            nervous because you don't normally have a pallet of cement
            hanging over your home and there may be some risk that the
            cable will break.  Because you're concerned about your family's
            well being, you'd, probably like to get rid of it completely but let's
            assume that it would be too difficult or unaffordable. Then
            you'll probably try to do something like reinforce the cable or
            reduce the load so that you increase your confidence that your
            family won't get hurt This is an unlikely example, but as an
            illustration, it may be useful It is similar to our situation with
            DNCintheair.  In that situation, the the weight of the cement
            or DNC contamination is closer to 500 Ibs and our dean up plan
            calls for the cement or DNC to be reduced to less than 5 Ib. Even
            with. 5QQ Ibs of <***™«*»t there is still, some small fha«^ that the
            cable might break, and reducing the weight to less than 5 Ib
            would greatly reduce that chance. In other words, for our
            situation around the Electrobotics Plant, we think it is presently
            safe, but we would feel much more  confident about everyone's
            safety over the long term, if we could make it safer by further
            reducing the contamination of DNC That is what we are trying
            to do. Even though this example doesn't give you a precise
            answer to what 1Q"6 is, I hope it gives you a better idea of how
            small 10"* risk is, and why we are proposing these actions.

            As in any response, this one may not be satisfying to everyone,
            and you may need to be prepared to offer other examples  to be
            more helpful. For example:

     A.    RJoflks, |ike that analogy wasn't too good for everyone^ Maybe
            some of you now have some more specific questions that could
            help me to explain this better, or maybe I could meet with those
            of you who would like to discuss it further after this meeting.
            If you want I could give you another example?

            Other examples: A10"* risk level is equal to the risk level
            associated with EPA's drinking water standard for TCE, a
            probable human carcinogen; or 100 times more stringent than
            EPA's drinking water standard for vinyl chloride, another cancer
            causing rfarniral; or 10 times more stringent that EPA's air
            standard for benzene, also a carcinogen.

•Pnbljc Meeting: Typical QoeAioa* and Single Responses.* By Alvin Chun and Arnold R. Deo. Office of (be Regional Admini«r.M.
Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

        A.    Poor Response:  It's almost like getting four-of-a-kind in a
              poker game. (If people are expressing doubt or confusion about
              the terms, and you proceed to explain the terms with more
              unfamiliar or technical terms instead of looking for a more
              rclatable explanation or example, it will be non-productive and
              create outrage.)

  10.    Q.    Am I the fme-umnfflion? Why isn't it zero?

        Underlying Public Need:  The public is concerned about haw they will
       . be affected  personally, and whether they can trust the Agency's
        judgement   The public may also be giving an indication that  they
        might  be interested in being more involved in the risk management
        process to decide on an "acceptable" risk.

        A,    Your concerns about how th<* risk nUITtb**rS would affect vou
              personally is a very valid one. Because we are talking
              "probability" or "chance" when we talk about risk, there is
              unfortunately no definite answer to your questions. But based
              on the safety factors we've used to develop these risk numbers,
              we sincerely doubt if you will get cancer from DNC Let me
              explain why.  In estimating the risk, we've made numerous
              health protective assumptions and assumed several worst case
              exposure tiftia*ifns to be on the safe side.  The *sg1iTf
      A.    Poor Response: Chances are you will not be the one-in-a-
            million to get cancer from being exposed to DNC. You're more
            likely to get cancer from eating peanut butter or charcoal broiled
            steaks which also contain carcinogens.

IL    Q.    What does  1 ppb mean; 1 ug/1; 1 ug/m3?

            (The context of this question is that we've been using 1 ppm in
            all our previous discussions and now we've introduced 1 ppb.
            This is a technical question requiring a technical answer which
            should be given in terms that are familiar to the audience.  The
            second response provided below can also be used to clarify "ppb"
            when it  is introduced in a public discussion.)

            For example,
fm SOTTV if we've confused things bv switching from 1 ppm to
1 ppb concentration. Here's one way to explain it:

            1 ppm is 1000 ppb, or
            1 ppb is a 1000 times smaller than 1 ppm

Another way to visualize 1 ppm is that is it is 1/1,000,000, and
this would make 1 ppb 1/1,000,000,000. (Write the numbers on a
flip chart to help illustrate your points*}

Even though these may be small numbers or small
concentrations, a small concentration of a certain toxic chemical
may still hurt you. Whether it can hurt you depends on the
chemical, how much and how long you're exposed to it

1 ppb is a Us UL for expressing concentration. 1 ppb is similar to
one drop of water in an Olympic size swimming pool, 1 second
in 32 years, or 1 item out of a billion of those items. I hope these
examples are of some help. (CR4,7)

Does mat dear up the confusion?  (CR 3,4,7)

Poor Response:  (Answering with technical terms or jargon
similar to the previous response when the question was actually
a non-technical question is a poor response because it doesn't
                    -of flv
'Public Mcetiag: Typical Question* tnd Sample Responses.* By AJvio Chun and Arnold R. Deo, Office of the Regional
Office of the Senior Science Advisor. EPA Region 9, revised January 1991

   12.    Q.    What does RCRA mean?

         A.    See Answers to Question* #11. (Avoid jargon and explain terms
              early in your presentation. Referring to "RCRA" as the "law" or
              the "regulations" may also be sufficient and won't sound so
              jargony once people are familiar with your term.)  (CR 7)

   13.    Q.    How can you trust the company?

         Underlying Public Need:   The public needs  to know that our primary
         concern is for their health and well being.  They would also like to
         know how we verify  company data.

         A.    You're concerned about the credibility of the company's data.
              Let me assure you that we don't take the company's data on face
              value. We critically review the data and the process by which it
              was derived to ensure its credibility. If we had any doubts, we
              would get additional, more reliable data. Our goal is to protect
              your health by ensuring that we* have the most reliable data
              from which to base our decisions. Unfortunately, because we
              have a limited budget and there are more environmental
              problems than we can address, we usually rely on company data
              and we do our best to ensure its quality.  (CR 3,4)

         A.    Poor Response Why do you think we trust the company?
              (Defensive, arid does not answer the question.)

   14.    Q.    Why did the company have to tell you? Why didn't you spot
              the problem and why did it take so long?

         Underlying Public Need:   The public probably needs to vent their
        frustration about the situation, and to feel that we have been and are
         currently doing everytliing that  we can.  They may need an honest
         apology from the agency for any delays,  and to know more
         periodically that progress is being made.

         A.    You would have wanted us to have known about the problem
              earlier. We wish we could have also. Unfortunately, we operate
              under limitations.  (As some examples: We didn't have any
              authority in this matter until recently when the regulations
              came into affect; Nobody knew DNC was a carcinogen until
              recently when the cancer data was published; and. We have
              limited •ywr?* to deal with these, problems^  However, we
              are t^V***^ actions to solve the probiemv and here's what we are
              doing to protect your health: -....—...........—......	(CR 3,4,7)

'Public Meeting: Typical Questions ud Sample Response*.' By Alvio Quia and Arnold R. Den. Office of die Regional AdnuoutriK*
Office of die Senior Science Advisor. EPA Region 9. revised Jaauary 1992.

       A.    Poor Response: We're doing the best we can, and I would
             appreciate it if you could be patient and try to understand that we
             are doing our best.

       Q.    What does 0.07 deaths mean? How. can you have a partial

       Underlying Public Need:  The public is confused by the information
       end would like clarification so that  they can better understand it,

             (A suggestion here is to it! vise the presentation and increase
             the population size even if it is larger than the real population
             to make 0.07 be a whole number. For example, 7 out of 100
             million would be less confusing.)
             I apologize for our poor example. Another way that may help to
             explain what we mean is to say that out of a population of 100
             million people who might be exposed to this chemical, we might
             expect that no more that 7 cancer would result in a lifetime.  So
             for a population of 100,000, it would be unlikely that there would
             be any cancers attributed to exposures to this chemical.  Does that
             explain it better? (CR3, 4, 7)

             Poor Response:  I'm not sure. (Even though this may be an
             honest response, it is embarrassing that such a basic question
             could not have been answered;  this hurts credibility. The public
             would have expected  an. agency representative to have answered
             Poor Response: Of the 100,000 people that would be exposed, a
             maximum of 0.07 deaths might result
16.    Q.    What do you mean you don't know?

       Underlying Public Need:  The public probably needs to vent their
       frustration and concerns, and may also need a genuine  apology from
       agency officials^.  IMPORTANT RULE: If you don't know, you should
       be open, honest, and fran]^ and say so.  You may have to repeat this
       several times, but never fuess or makeup an answer because '^vou 'feel
       vressurcd: this is a sure way of losing Jinv trust and credibility vou mav
       have established.
       A.    Tm sorry I don't have the answer today. Would it be OJC if I
             called you next week after I've done some checking to see if I can
             get the answer far you. May I see you after this meeting and get
             your phone number? (CR3,4,7)

"PubUc Meeting: Typical Questions and Staple Responses," By Alvia Qiao ud Arnold R. Den. Office of the Regional Adininisirauv
Office of the Senior Science Advisor. EPA Region 9, revised Juuiry 1991

  19.   Q.    One of our very dose friends who lived near the hazardous
              waste site just died from cancer.  (Person breaks down in tears.)
              How long are you bureaucrats going to take before we see some
              action? How many more people must die? We're taxpayers and
              we pay your salaries! I'm totally frustrated and angered by the
              amount of pressure we need to put on your office who we pay
              before we can get any action. What do you have to say for
              yourself?  I want to hear! (Person breaks out into tears J

        Underlying Individual Need:  The individual is very upset about  the
        loss of a dear friend,  and is probably needing, most of all, some place
        to vent their  legitimate emotions, and perhaps to get  some
        compassionate response.

        A.    Silence, (No response is needed or expected. One can. satisfy the
              person's need for compassion by genuinely listening with
              empathy until the person stops.  While listening, you may  hear
              and decide that people may want to know more frequently what
              is being done* and what the schedule for future action is.
           •   Providing that information later may give people a better idea
              that things are being done and when they can expect them to be
              completed. Often times, not regularly presenting that
              information, will give people a false impression that nothing or
              very little is being done.) (Principle:  Listen with compassion.)

        A.    (Oner listens and* allows the individual to vent eniutiuiis, and
              empathically responds:)
                 sorrv for vour loss. If you would like, we could discuss this
              some more after the meeting. (Principle: Listen and respond
              with compassion.)  (CR3, 4, 7)

              (One listens and allows the individual to vent emotions before
              empathically  responding:)
              This is an espedallv sad and difficult tjjrtfr for you. Fm so sorry
              for your loss. (CR3, 4, 7)

        A.    (One just keeps quiet.)  (Because you may have been surprised by
              the emotional outburst, and may not know what to say, being
              quiet is the next best thing to do, given that no response was
              expected. Being quiet may also be hard to do because one may
              feel mat a, response was expected. Most of the time, all a grieving
              person wants is just a chance to vent their emotions and to share
              their grief.) (CR3,4,7) _ _ _ .-    .
    Meeuug: Typical Qoemoas aad Single Respoaset.* By AJvia Chun and Arnold R. Dea. Office of the Regional Admiainraicr.
Office of the Seaior Science Advisor. EPA Retioe 9. ttvited Juuwy 1991

       A.    Poor Response: (Interrupts the individual and gets somewhat

             We're doing the best we can. Why, last week we finished the
             proposed permit, report or RI/F5, and by next month we should
             be making a decision.  Please be patient with us.

       A.    Poor Response: I'm sorry your friend died, but all of you should
             know that 1 out 4 of you will get cancer in your lifetime anyway
             from normal dairy activities. Specifically, for the hazardous
             waste site, the added lifetime risk of getting cancer is only 1 in
     -•        10,000. Since there are 5,900 people in this community, we
             would not statistically expect to see any excess cancers in such a
             small population.

       A.    Poor Response: I'm sorry your friend died, but it probably
             wasn't because of the hazardous waste site because it's only been
             there for 5 years and it normally takes 15 years or longer for
             someone to develop cancer. We are doing everything we can.

       A. *   Poor Response: Your friend's death is unfortunate, but you
             shouldn't be blaming us or the hazardous waste site because we
             had nothing to do with it

20. *  Q.    You don't have to live in our neighborhood! You don't have to
             deal with the stigma associated with this hazardous waste site!
             ISre got my life savings tied up in, my luune! Would gou live
             here? Would you buy my home?

       Underlying Individual Need:  This person is very concerned  about
       their  property losing some  of its value, and  would like to know if the
       Agency is  doing  everything possible  to  ensure that property values will
       be protected, \*., Are you, as the Agency representative, doing as much
       for the. neighborhood as you.  would if you wot a resident?

       A.    Sir, it sounds like vou'd  like to know if I would buv a home
             here, but I think your real question or concern is about the type
             of dean up we will be doing to ensure that your property values
             are not affected, and that are we doing everything we possibly
             can.  Would answering  that question be more helpful?
             (CR 1,3,4,7)
             Option 1.    If so, here's what we are doing:....	 I would
             like to stress that our goal is to ensure that your environment is
             Safe ttt live in. lit Ofhtri*ffyf)d% *Q ^wm^^t"** *k^ arcymi-tmaath^
             the soil that your children play in, and the water that you drink

"Public Meetiag: Typical Question* aad Simple Responses.* By AJvin Chun ud Arnold R. Den. Office of the Regional Adrainutraii*
Office of the Senior Science Adviser. EPA Region 9. revised January 1992.

      A.    You sound very disappointed, but I'm sorry, science just doesn't
            have all of the answers for us. (CR 3,4,7)

      A.    Poor Response:  We don't know, and you can't expect me to
            know everything.  (A rational response in this case fuels more
            anger when all people probably needed was an opportunity to
            vent their frustrations; any sarcasm added to the rational
            response just makes the situation even worse.)

17.   Q    If we can't get action from EPA on maintaining the value of our
            property, who can we go to?

      Underlying Public Concern:  The public is  no longer just outraged, but
      they are not* ready to consider solving the problem.  They also  realize
      that EPA can't do all they had initially expected.

      A.    I share vbur concerns about the value of vour property. We are
            trying to protect your health and in  doing so, we may  have to
            consider some remedies that may not make you happy but will
            protect your health. Our goal is to find a remedy that  will protect
            your health and not affect your property  values; but our primary
                 RI is with your health. Your ideas and input will help us
            make the best decision.  I encourage you to comment on the
            options that we will be considering, and I hope that in doing so
            we can correct this problem to your satisfaction. (CR 3,4,7)

      A.    I know you are concerned about the future value of your
            property. Even though we can't do anything directly about your
            property values, here are some suggestions:
                                 which may be helpful  Are there other
            ideas that someone else would care to offer? (CR 1,3,4,7)

      A.    Poor Response:  We have been working hard to solve the
            hazardous waste problems.  Right now I'm working on 5 other
            NFL sites and your site is getting most of my attention. We
            don't have legal authority to address your property value
            concerns. (We're not listening to people's needs and reacting
            naturally, and inappropriately being defensive; this tends to
            create a negative perception  that we're unwilling to consider or
            mmgiitfr with; other credible sources when it is
 "Public Meeting: Typical Qtieniosi and Simple Rejponiej." By Alvio Chun and Anold R. Den. Office of the Regional Adnuoisuu t
 Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

 18.   Q.    IVe been working here for 15 years and I'm fine.  How can you
             say there's a problem?

       Underlying Public Need:  The public needs to know haw credible we
       and our science ore,  (This person's question may also represent some
       initial denial of the risk at hand, or a concern about their job.)

       A.    Sir. I'm very happy that you are fine, and I hope you remain
             that way. Unfortunately, I can't make that assumption about
             everyone else because some of your fellow residents may not be
             as healthy as you, and we must be cautious to ensure that
             everyone's health is being protected.

             In saying that DNC is a probable carcinogen and that it has
             contaminated the air, we are not trying to create more of a'
             problem.  Unfortunately, science doesn't have all the answers
             that you and I would like, but we have to deal with that. In
             dealing with this, we use many health protective assumptions
             to make up for the uncertainties that remain in science.  In our
             deliberation and examination of the health effects information
             related to DNC, we believe that it is a carcinogen which should
             be-treated seriously. We do this to ensure that you and your
             family do not suffer from any future health problems.  Because
             of the uncertainty in science about the causes of cancer, your
             statement of good health doesn't surprise me. Unfortunately,  I
             cannot say with your degree of confidence that DNC is safe; the
             health data says we should treat DNC contamination with
             caution.  Our goal is. to .ensure that you, your family and
             eteiyoiie is your community can say with your degree of
             confidence that the DNC exposure is so small that it doesn't
             pose a danger. (CR3,4,7)

      A.    Poor Response:  Your case is an exception.  Our animal studies
             combined with our use of health protective assumptions in the
             risk assessment indicate that there is a cancer risk which may not
             be seen for another 20-30 years. (Even though you understand
             risk assessment, being argumentative and not acknowledging
             people's views can create obstacles in future communications.
             In. this-casCr it creates unnecessary oz faic^ mm-on^ \
"Public Meeting: Typical Question and Simple Response.* By AJvin Qina and Arnold R. Den. Office of the Regional Admioimatur
Office of the Senior Science Advisor, EPA-Regjon 9. revised January 1992.

          are safe. We wouldn't like your property values to decline, and
          returning your environment to a healthful state or preventing it
          from being unsafe is our responsibility, and this is what we can
          offer to help protect your property values. As you know, there
          are other factors which also afreet piopetly values such as public
          perception which unfortunately neither you or we have any
          control over.

          Option 2.   If not, I don't know if I can really answer your
          question about whether I would buy a house here because  like
          other major investments there's many things to consider such
          as schools, employment, environment, etc, before I could  make
          such a derision. I know that if I were living, here or if I had to
          buy a home here, I would at a minimum want the environment
          to be safe, and that is the goal of our Agency: to ensure that your
          environment is safe.

    A.   Jhis whple situation has not been an easy or pleasant pne  for
          you, and we're also very concerned. As to whether I would live
          or buy t home here, that's usually a very complex question for
          moot situations.  But if my only considerations for «**it«i»g a  .
          decision were whether the air was safe to breath or the water safe
          to drink, I would say yes because our Agency's goal is to ensure
          that it is. As you know, there are other important and personal
          considerations such as cost, neighborhood, quality of schools,
          mortgage rates, etc, which most of us take into account before
          deciding on the purchase of a home (CR 1,3,4,7)

    A.   Poor Response  Personally, I wouldn't Eve here  that's off the
          record, of course

    A.   Poor Response:  (You appear to be caught off guard and seem to
          be searching for an answer but can't give one, or are afraid to.
          This may give the community a false impression that you
          wouldn't ever buy a home here because the clean-up will  not be

    A.   Poor Response:  Property values are beyond our control and not
                             Tnx soxry we '•HIP™** h»in you.
"Public Meetiag: Typical Questions tod Sample Responses." By Alvin Chun ud AraoU R. Den. Office of the Region! Administrator,
Office of ihe Senior Science Advisor, EPA Region 9. revised Juuary 1991

21.*  Q.    I am considering buying some property here. Given all that has
            happened, would you buy or recommend buying property here
            now ox in the future?

      Underlying Individual Need:  This person is  concerned about
      investing his money here, and would like to know if that would be a
      wise thing to do.

      A.    Property investments are important transactions requiring
            careful consideration. I can appreciate  your concern. Property
            investments are also very personal choices. Where I may be
            willing to invest my money may be very different from where
            you or someone else might be willing to invest their's. For me
            to tell you how you should spend your money would probably
            not be very helpful because I'm not very knowledgeable in that
            area, nor do I know what criteria you consider important.  What
            I think would be more helpful would be to give you all the
            information about the hazardous waste problem that we have so
            that you or another potential buyer or  seller can make the most
            informed choice possible. (CR 1,3,4,7)

      A.    Poor Response: Sony, but we dont make those types of
            recommendations.  (Even though mis is true, it does not address
            the individual's underlying need, and  may give the impression
            that you wouldn't recommend buying  property here.  In the
            preceding answer, the response w.as not only honest, but it also
            offered information that was helpful.)
             Chief, Public Putidpctton
             California Dcpulrcil of Toxic Subrtancv Control
 •Public Mewing: Typical Question* and Swnple Response*" By Alvio Chun ud Arnold R. Deo. Office of (he Regional Admiunrai.«
 Office of the Senior Science Advisor, EPA Region 9. revised January 1992. •

                        THE STATE UNIVERSITY OF NEW JERSEY
                   Environmental Communication Research Program
                    A program of the Agricultural Experiment Station
      Cook College • 122 Ryders Lone • New Brunswick • New Jersey 08903 • 201/9324795

       Decisions about when to release information depend* In/large part, on the
 situation:; However; agencies should seriously examine the Implications of:holding onto
 information. The nest time you contemplate whether to make information-public.
 consider, some of the reasons to release Information early:  :    '    .
 1.     People are entitled to Information that affects their lives;:

2.     Early release of information sets the pace for resolution of the problem,

3.     If you wait, the story may leak anyway.  When it does, you are apt to lose trust
       and credibility.

   ir   You can better control the accuracy of information if you are the first to present:
       it.:      '   •                    .        .-.- :-••••-•••• •<•:: '••'••'• ' '

       There is more likely to be time for meaningful public Involvement In decision*
;      , making if the information is released promptly.            7l

6.     Prompt release of Information about one situation may prevent similar situ*
       atlons elsewhere.

7.     Less work is required to release information early than to respond to Inquiries.
       attacks, etc. that might result from delayed release;:

8.     You are more apt to earn public trust if you release information promptly.

9,     If you wait, people may feel angry and resentful about not learning of the infor-
-."..   •  matlonearlier;                 •     ' ••.   ;'::':•/-. .''W^--i
10.   People are more likely to overestimate the risk if you: hold onto information.
 Froare. Chess,- Hance, B.J., and1 Sandman, .P.M.;; /'Dt^jroving. Oiaioguie..With;
 Communities^   A  Short. Guide For Govermnant:: Risk: Communication," CTrenton,, NJ,
 Divisipa of: Science and. Research,: NJ Department .of ::Sav.ironniental .Protection,
 '                                  '      •


                      FOCUS GROUP TBCHHIQOB
     A focus group is an in-depth, interactive discussion among
peers (e.g., CEOs, doctors, homeowners) guided by .an experienced
researcher  (moderator).  A session generally lasts ninety minutes
and is comprised of 8 to 10 consumers or 6 to 8 business execu-
tives.  Interaction among the respondents is a key element of a
focus group and the moderator is the major catalyst to this pro-
cess. .                     •  '          '           •

     The focus group moderator works from a guide developed in
conjunction with the client.   This guide outlines the pertinent
topics and issues to be discussed.  The moderator begins a ses-
sioji with introductory comments designed to relax the partici-*-
pants and set the stage.  These remarks include a description of
the focus group technique and the importance of candid responses
by the group members.  Then participants usually introduce them-
selves.             '            •     •

     The discussion is typically opened with a general subject
that is easy to talk about and to gain perspective from which to
evaluate subsequent information.

     The interactive process  in focus groups makes it possible to
obtain information to fulfill specific study objectives as well
as to gain insight into other issues which could have an impact
upon the research.  Thus, a great depth and breadth of knowledge
can be obtained through this  process, including discovery of in-
formation not previously recognized as significant or connected
to the key concerns of the client.

     Focus group participants are usually recruited by a local
market research first which screens potential respondents to in-
sure that they meet the specifications (e.g., watch television
news, are dog owners, use personal computers).  These homogeneous
groups allow researchers to hear, first-hand, responses from
those who have had similar experiences regarding the topic under
discussion.  Homogeneity also enhances relaxation among the group
members and serves to contribute to an easy exchange of ideas and

     Participants in focus groups typically receive a monetary
incentive, usually $30 for consumers and between $50 and -$200 for
executives and other professionals attending in their business
roles.  In many instances, particularly with business executives,
the opportunity to discuss a specific topic with their peers is
almost incentive enough to ensure enthusiastic participation.

     Focus group facilities contain conference rooms where the
session takes place.  Adjacent to the session room is an observa-
tion room where clients can watch the group via a one-way mirror.
This allows observers to note subuties in facial expressions,
body language and tone of voice among the respondents.  In
addition, the group is audio taped for use in analyzing the data
and as a record of the session.

     Video-taping can also be accomplished by filming through the
one-way mirror.  By recording the meeting on tape, others can
view the session who are unable to attend the focus group.
(Respondents are informed about all these facets of the process
but are not told the identity of the client.)

     The  focus group technique is often  used to gain  insight  and
provide direction for marketing strategy and further  research.
However, conclusions must be tempered by the limited  cample size
inherent  in this type of  research.  Thus,  findings must be  viewed
as quantitative in nature  and not  necessarily  representative of
a.larger  population.

   EPA Title m Focus Group Results
     What son of information can you expect to get out of a focus group? The results
   from a series of focus groups in 1988 can give you a good idea of the amount and
   quality of information focus groups generate.
                                                     *            • -
     The report about the six focus groups includes hard data ("half of the people said
   they had never heard of the chemical").  It also includes conclusions  ("stores might
   therefore be the best places to distribute  information").   The focus groups  were
   conducted by Campbell Communications, Inc. and sponsored in pan by the Environ-
   mental Protection Agency.

     The six focus groups were conducted to  assess  the need for risk communication
   with  the general public  in  four neighborhoods,  two  in  New Jersey and  two in
   Pennsylvania. They were conducted in  light of the fact that plants would soon be
   releasing information as a result of SARA Title IE.

     The focus groups were pan of a comprehensive study that  included a review of
   existing survey data, interviews with government officials about their perceptions of
   the public's need for information, creation of a communications  manual, and creation
   of a bibliography of public education materials. Additional focus groups with health
   professionals, environmentalists and other specialized groups also were pan of the

     In this section, we address what information the six focus  groups with just the
   general public yielded. The participants were carefully selected to be a random sample
   of the general public — for example, they were not employees of nearby plants • or
   predominantly college graduates.
Adapted  from material prepared  for the Environmental  Protection
Agency by Elaine Arkin and David McCallum.   As adapted and
reprinted in the Risk Communication  Student Manual, edited  by
Erin Donovan,  Vincent Covello and John Slavic*  (Chemical
Manufacturers  Association, Washington, DC  1989).

Who Gets Selected for Focus Groups?

   About 10 people were selected for each of the focus groups. A trained moderator
initiated and directed discussion.

   All of the participants lived within one-half mile  of a company expected to be
reporting under SARA guidelines. This proximity makes this subgroup of the "genera)
public"  the most likely  to  be  affected by emissions.   These plant neighbors were
perceived as having a high priority for risk communication efforts for several reasons:

   •   their residence

   •   the meaning and  implications of toxic substance emissions

   •   their low awareness  of the new reporting requirements

   •   their relatively low levels of concern for personal/family safety (the focus groups
       confirmed these two alarming assumptions)

   •   high levels of frustration about the nearby residents' ability to obtain, understand
       or trust emissions information

   These were the assumptions going into the study. The focus groups confirmed the
final three, somewhat alarming, assumptions.


   Focus group questions elicited information about the participants' awareness and
attitudes.  It was determined that:

   •   No one in the groups had heard of SARA Tide HI reporting requirements.
       When informed, though, their response was positive.

   •   Awareness of community emergency planning and procedures was low.

   •   Respondents held misconceptions about permitted emissions and tended to
       believe anv  emissions were  illegal.  When  told some  emissions are  legal,
       participants were critical of laws allowing emissions.

   •   Participants expressed very little curiosity about levels or length of exposure,
       or other factors affecting risk.  In fact, the few questions raise suggested that
       these participants might have difficulty both in articulating questions about toxic
       substances and understanding the answers.

   •   Participants were very unaware of specific toxic substances, their uses and risks.

   •   Most participants did not distinguish  between toxic  chemicals  and  other
       pollutants, like sewage or automobile exhaust.

   •   Generally, focus group respondents perceived EPA  as "on the side of big
       business." The did not seem to believe that regulations to date have favorably
       affected environmental quality.

   •   Attitudes'toward industry were mixed.  Those living in a community where
       chemical companies are the main  employers were inclined to menton that
       companies are "better than they used to be" about emissions and clean-up.

   •   Generally, participants believe that the responsibility for environmental quality
       belongs to "someone else." There was no incentive, benefit or compelling reason
       for them to become involved.

   •   Some participants remarked  at the close  of discussions that the focus group
       had heightened their interest in the issues raised.  Generally, interest  and
       awareness was low.


   Focus group discussion tried to address the level of the participants' concern about
chemicals and their behavior based on those concerns. The focus groups found:

   •   Most respondents were concerned about environmental pollution.  But  they
       were equally  concerned  about all  kinds  of contaminants, including  toxic
       chemicals, garbage and pesticides.

   •   Many people did not mention concern for personal or family health.  Many
       had lived in their communities for a  long time and accepted emissions as "a
       fact of life."

   •   Many participants thought there is little they can  do to change things like
       pollution from nearby plants.

   •   In  one  community where pollutants in drinking  water, had been publicized,
       however, many participants said they were using bottled water. This shows that
       in a case where individuals feel there is a specific action they can take, they may

   •   Some  participants  said   they  had sought  information  about  a  perceived
       environmental problem and were discouraged by their inability to get answers.

   •   Participants were skeptical that the  new reporting  requirements would yield
       them accurate data or  prompt enforcement of emissions laws.

Information Sources/Distribution Routes

   The focus groups elicited information about how people learn about environmental
issues. If indeed the participants are representative of the community (as they should
be in a professional, well-designed focus group), the data can be used to help tailor a
more effective, efficient risk communication program.  These six focus groups found:

   •  Most people got information about environmental issues from the media.

   •  Those who described frustrating experiences with information-seeking efforts
      said they had called a local government agency or the company.  No successful
      experiences with these contacts were described.

   •  When asked by the moderator where else they might seek information, the only
      source mentioned by all six focus groups was the police. No one mentioned the
      fire department,, the 911  emergency  number,  health  departments, elected
      officials, libraries or other sources.

   •  When asked which environmental groups they could contact for information,
      answers included Common Cause, Greenpeace, Sierra dub, and Ralph Nader.
      No one mentioned a local group or a local chapter of a national group.
   m  Environmental groups were  the only sources cited as credible.

   •  EPA, companies, and elected officials were consistently viewed as the least
      credible sources of information.

   •  Asked where they  would like to obtain information about  the environment,
      participants most often mentioned the  places they frequent.  The best places
      to distribute information therefore might be supermarkets,  drugstores, malls
      and other public places.

Risk Communication Strategies

   The focus groups generated basic, useful  information to help the nearby plants
design risk communications programs.

   •  There must be a personally relevant need for risk information for someone to
      ,       v          ^^^^~--   -
      be motivated to learn more.  Participants said a need might arise if they see
      evidence of emissions and water pollution. They said protection of their health
      and their children's health might motivate them.

   •  Protecting  property  value  was  -not  considered  a motivator for  seeking
      information,          .

   •  When information-seeking or other actions are perceived as needed or beneficial
      and the participant feels that he or she can have an effect, the participants will
      probably be more likely to act.

   •  Although printed information may help, one-on-one interaction may be required
      to truly inform people.

   •  There must be an information source who is easily accessible, knowledgeable
      and credible if the target audience is to be expected to become more interested
      and informed.

Risk Communication Message and Materials

   Comments from the focus groups enable the moderator to suggest realistic steps
for better risk communication.

   •   Members of the audience targeted by the focus groups are more likely to be
      less affluent and less educated than the general public Information targeted
      for them therefore must be simple, clear and easy to read and understand.

   •   Materials should be pre-tested with the intended audience to assure that they
      meet these criteria and that they respond to the requirement for a nsfid to read
      and a benefit from reading.

   •   Information should be prepared to:
      •  explain why some releases are permitted;
      •  explain what effects regulations are having in improving the environment;
      -  explain why some emissions are more hazardous than others and what the
           hazards argj
      •  cite the differences between emission and exposure;
      •  cite other health risk factors;
      -  explain what SARA Title m is intended to do and why it is relevant, useful
           and important;
      •  provide a reliable, accessible information source and how he or she can b e
      .  use a question-and-answer format to help the reader understand the  issues;
      •  tell the reader what to ask or what personally relevant action to take in the
           event of an emergency
      •  provide a glossary.


 Risk Anatvsu. Vui. 8. .Vo. 4. 19(18
    est Editorial
Focus Groups and Risk Communication:
The "Science"  of Listening to Data

William H. Desvousges1 and V. Kerry Smith'

    Focus groups are old hat in market research.
These small group discussions are commonly used to
help companies learn how consumers feel about van*
ous products or services and to develop survey ques-
UuutMJres. Researchers interested in understanding
now people respond to  environmental risks  have
    itiy begun using focus groups because they offer
    its into how people process information or an-
swer questions.    .                      s
    Focus groups **aT> also nuke risk communication
more  effective by helping communicators listen to
"consumers" of risk messages. Too  often, risk  com-
municators are more concerned with educating the
public, rather than fust listening to them and then
developing communication policies. Focus groups al-
low the consumers of risk messages or communica-
tion programs, to provide critiques and feedback to
their designers. Using feedback from focus groups,
researchers can gain qualitative insights on how peo-
ple perceive risk, as well as evaluations of the percep-
tual or cognitive effects of the risk information for-
mat. Such feedback is crucial to rf>mmiinin"nB risks
more effectively.
    To develop  our arguments, we have drawn on
our experiences with focus groups over the past five
years. We suggest six applications in  which  using

1 Senior Economist. Research Triangle Institute. P.O. Bo>  12194.
Research Triangle Park. North Carolina 27709.
 University Distinguished Professor. North Carolina Suie Univer-
sity. Raleigh. Nona Carolina 2769$.
focus groups can  make risk  communication  more
effective. We also offer some rules  of  thumb for
conducting focus groups, based on what has worked
and what has not.  Finally, we develop some general
implications for the role  of  focus  groups in risk

     Focus groups are informal discussions in which
a  skilled  moderator probes people's attitudes and
opinions on a specific topic. Usually lasting about
two hours, (he group are relatively small. The ideal
group size is eight to ten people. The objectives for a
session  may range from learning  about  consumers'
reactions  to  a new snack  cracker to  discovering
homeowners' attitudes toward a high-level  nuclear
waste repository.  In general, focus groups allow peo-
ple who must convey information or market products
to test their concepts on consumers before making a
final de
    Over a one- to two-week period, organizers re-
cruit participants to attend the session at a conve-
nient (for the participants) location. Participants are
recruited  to  represent  either  a specific  target
.group—e.g^ health can professionals or retirees—or
the general population in an area. They can be ran-
domly recruited by telephone or by working through
civic, religious, social, or professional organizations.
    Effective moderators are crucial to the success
of the  session.' Using an agenda, they open the dis-
cussion with questions and keep it on track by selec*
                                                            0271.4m/a/l2(XMM7«B)6.aO/l tl«M Sean* tar RJ*

                                                                                  Desvousges and Smith
lively focusing on  various respondents'  comments.
The most difficult task for a moderator is to stimu-
late discussion without  biasing  participants'  re*
sponses. Moderators can work alone or  lead  the
session together. It is especially important that mod-
erators  not be perceived as experts  because people
will quickly turn to them  for answers, rather than
discuss topics among themselves.
     The focus group formal is very flexible,  On
risk-communication topics, participants can be asked
to write down their answers to survey questions and
then discuss them. Or, they can be asked to critique
public service messages for radio,  television, and
newspapers. However, sessions can also be designed
to promote relatively free-flowing discussions about
how people perceive the risks from exposure to some
hazardous  substance.  Tasks  or  exercises are often
used to stimulate discussion or evaluate  (qualita-
tively) how people process certain types of informa-
     Despite their widespread use in market research.
focus groups have only recently been considered in
risk communication. Drawing from experience  in
marketing research and more limited experience in
risk studies, we have identified the following six
areas for using focus groups:

    . •  Exploring risk perceptions.
     •  Evaluating perceptual cues  and information
     *  Pretesting n**f-jrirynfp"niraTtfin materials.
     •  Sclenting risk-communication
     •  Designing risk-mitigation policies.
3.1. Exploring Risk Per

    Focus groups can be especially effective in ex-
ploring people's perceptions of risk. Our focus groups
on hazardous waste risks and radon risks have yielded
several important insights into how people perceive
each of these risks  that would have been  hard to
detect with conventional survey procedures. For ex-
ample, we found that people form concrete images of
hazardous  waste. These 'tnaflpy' are igygEtcd  with
rusted barrels of chemicals, or empty houses from the
well-publicized experiences at communities such ast
Times  Beach.  Love Canal, or Wobum. In contrast.
people could not easily form images of radon, which
made it difficult for them to evaluate their risks from
radon. One focus group participant's  comment was
especially revealing: " It's easy to put off because you
can't see or smell it. The health risk lakes a very long
    We also found that people had difficulty relating
government regulations to risks from hazardous waste
exposure. Over the course of  several sessions,  we
tried several ways to make the connections clearer.
Ultimately, we used concrete examples to show link-
ages between  regulations, exposures,  and potential
health  effects.
    In addition to probing risk perceptions,  focus
groups provide an opportunity to evaluate how those
perceptions are linked to personal attitudes and char-  '
acteristics.  We were able to develop  ideas about how
age, or experience, may affect risk perceptions. These
ideas  led  to hypotheses  that were explored  more
formally in surveys.
    Focus groups  "!**> highlighted differences  be-
tween  tffhnir*! risk assessments v^ people's risk
pfrcr ptiOTf Some technicians argued  that, if people
only understood that the probabilities of dying from
exposure to hazardous wastes are much smaller than
the probabilities of dying from an  automobile acci-
dent, tfafg we could communicate  risk more  effec-
tively.  They placed primary (if not complete) weightl
on the importance of the magnitude of the probabil-  >
tty estimate. In contrast, the lay public appears to use  i
multiple criteria—the probability, the potential con-
sequences (e.g* cancer or birth defects), the extent of  •
individual  control, the time to resolution, and others
—to rate the risk. More definitive answers about
these factors influence individuals' responses to risk
will require more systematic research.
    Focus groups also permit evaluations of visual
Focus Groups and Risk Communication
•                        '
     le interpret and use risk information. By using a i
sequence of several sessions with progressive modifi- i
caung materials, we found that some people pre- \
ferred verbal explanations  of the risks from haz-
ardous  waste exposure while  others  preferred the
visual representations provided by  the probability
wheels (risk circles) we had adapted to illustrate the
probabilities. Still others preferred representation in
mathematical terms: the percentage  of cases experi-
encing the outcome. When we used multiple cues to
characterize the same  risk concept, we learned that .
many people used the representation they found most .
comfortable and ignored the others.
     The process leading to our decision to include
both fractions and  percentages to explain risk to-
gether with the risk circles illustrates the value of the
focus groups. After conducting several sessions using
these circles  without  the percentages, we  noticed
when we collected the visual aids that many people
had calculated  the  percentages. In the next focus
group in  which we also  provided the percentages,
people discussed how they  used and interpreted ei-
ther the fractions, percentages, or both in evaluating
the risk information.
                                                                                          {.MOW 100.008
       testing Risk-Co
    Focus groups offer an excellent method to pretest
risk-communication  materials.  We have used them
with both well-defined, homogeneous target groups
and more heterogeneous  collections  of individuals.
For example, homeowners in high radon  areas pro-
vided useful suggestions for simplifying the language
and organization of several radon  brochures. Partici-
pants drawn  from a more heterogeneous range of
experiences had trouble recognizing the messages in
several radio  public service  advertisements because
of distracting background music. The same group,
however,  found  that  background sounds (people
rustling newspapers or placing coffee cups in saucers)
made other ads seem more realistic. These comments
were reflected in changes made in the final ads.
    Our experience with  focus groups suggests that
they can  be quite valuable in  evaluating different
ways to present risk concepts. In several focus groups,
we used risk ladders to elicit the perceived risk from
hazardous waste exposure. Participants in a progres-
sive  sequence of sessions taught us  that our first
ladder did not offer sufficiently diverse risk informa-
    kThey wanted more coverage of  the lower risks
                                                                                           ,01 •( 100 «
                                                                 Fig. L Final version of the rak Udder.
                                                      and wanted to find out about risks that were more
                                                      likdy related to their specific occupations. They also
                                                      suggested several changes in the ladder that resulted
                                                      in one consistent visual  focus on the center of the
                                                      ladder. Their comments indicated that breaks in the
                                                      ladder  would help  us to present a wide  range of
                                                      values while keeping the scale and transition between
                                                      levds understandable. We  also  found the use of
                                                      colors along the ladder helped reinforce the differ-
                                                      ences. Figure 1 shows our final ladder.
                                                           The focus group reactions to the different ver-
                                                      sions of the risk ladder also highlight an  important
                                                      limitation  on using risk ladders. People found the
                                                      ladder  useful in trying  to  think about their  own
                                                      situations. However, they emphasized that the ladder

                                                                                   DesTousges tad Smith
would not have worked as a communication device
for convincing them the risks from hazardous waste
would be acceptable because it includes risks with
very different characteristics. (We had included these
alternatives to provide the wider coverage of risks
requested by the earlier sessions.) Oeariy, improving
risk ladders, or other indices, is an area for further
research in which focus groups may continue to be a
valuable tooL
     The messages from focus groups are often nega-
tive—here's what  is not communicating. For exam-
ple, we learned that putting the risks from aflatoxin
in peanut butter was  a disastrous risk-communica-
tion idea. We lost control of a focus group as partici-
pants heatedly debated for over an hour why it was
included. In this case, hazardous wastes and peanut
butter did not mix. The comparison gave very mixed
signals which led  to contusion, not communication.
Clearly this comparison was a mistake, but it would
have been more serious had  it taken  place in the
actual survey, or  in a broader risk-communication
3.4. Selecting Risk-Comnninicmtioa Ot
     Focus groups are useful in selecting the poten-
 tial channels to be i ffd for romPTtitnicfl|t'aB  risk
 information. With radon, we found (perhaps not
 surprisingly) that no single channel was superior. For
 example several participants had obtained consider-
 able information about radon from listening to the
 radio. Others listened to the radio, but changed the
 station whenever  they r«wignr>gH something  as an
"ad." Some participants  seldom listened  to  their
radios at alL However,  some members of  this last
group had followed the  radon issue closely in their
newspapers.  Overall, these sessions  emphasized the
.importance of using multiple communication chan-
nels and adapting the message to meet the specific
needs of each channel — two basic tenets of the risk-
communication literature.

3.5. Designing Risk-Mitigttma Policies

     Focus groups provide preliminary feedback on
policies  that government or industry might consider
for mitigating risks. For  example,  we asked focus
group participants to rate  the potential effectiveness
of  various strategies for mitigating the risks  from
transporting high-level nuclear wastes. The partici-
pants consistently named several strategies,  particu-
larly those emphasizing state and local participation.
while they consistently regarded others as ineffective.
These patterns allowed us to narrow our attention
and  focus on fewer alternatives to  be  used in the
subsequent  survey research.  Because the findings
from focus groups cannot be generalized to a new set
of conditions or an entire population, they are espe-
cially effective when  combined  with other research
methods, such as surveys.

3.6. Assessing Risk-Communication Effectiveness

    One of  the most important, and  often neglected.
aspects of risk communication is assessing communi-
cation effectiveness. Focus groups can play two use-
ful roles in  the  evaluation process. As mentioned
earlier, they are helpful  in pretesting the messages.
But they can also help in designing survey question-
naires used to evaluate effectiveness of the communi-
cation program itself. Our experience suggests that
focus groups can reveal problems in question word-
ing, order, and format for these questions. They may
also generate unanticipated ideas for measuring ef-
fectiveness.  If the survey  involves in-person  inter-
views, focus groups can provide especially good ideas
for developing visual aids.
    Then is an  important caveat  to  our overall
support for the use of focus groups. Focus groups
alone are insufficient for evaluating the effectiveness of
a  risk communication program.  The findings from
these groups are qualitative. They need to  be but-
tressed with quantitative measures of effectiveness.
Moreover, focus group findings cannot be reliably
generalized  to a  population  because their sample
sizes are too small or their sample selection is non-
random. Thus, it is important to nrcognirft that eval-
uation provides one area where focus groups may be

    To help others iearn from  what worked and
what didn't we list some rules of thumb on imple-
menting focus groups:
    •   Work  with civic  groups,  church organiza-
        tions, and social organizations to reach target
        segments. Giving  guidelines  to organization

Focus Groups and Risk Communication
       contacts can help control group composition.
       By making a  modest  contribution to  the
       group (S100).  people feel a greater sense of
       responsibility for attending and contributing
       to the session.
    *  Keep  the groups relatively small. We have
       found that groups of eight to ten are most
    •  Send   people  a confirmation tetter and a
       brochure about your organization to reduce
       anxiety about  intentions. People invariably
       brought  the materials with them and  men-
       tioned after the session that they were less
       concerned.about  being  targeted for a sales
    *  Make sure the moderator is represented as a
       nonexpert in the risk area. Having people ask
       (he moderator questions severely reduces  the
       effectiveness of the session. We have also
       found  that, after observing several sessions, it
       is often possible, and indeed desirable, for a
       member  of the research team to assume  the
       moderator rale. This allows for more fieaubii-
       ity  in  following up unanticipated  areas of
       discussion that are  germane to the research
    *  Don't  try to hold focus  groups with respon-
       dents who might have difficulty with a topic.
       Generally, we  found these to  be the least
       informative sessions  because the participants
       were unable to verbalize why they were hav-
       ing difficulty or simply felt uncomfortable in
       a group  setting. One-on-one in-depth inter-
       views may be a better alternative for target-
       ing these individuals.
    •  Make sure the organizational structure of a
       group knows about the session and its objec-
       tive. No one showed up  for a session involv-
       ing high  school teachers because the t«*t*»T
       helping with the arrangements did not clear
       the session with the school principal. After
       learning  of  the session, the principal had
       threatened to  censure teachers  if  they  at-
    •  Arrange  for multiple records for each ses-
       sion. Videotaping, audiotaping, or having an-
       alysts  directly observe the sessions had  no
       effect  on the quality of the session.  When
       possible, videotape the sessions, as this pro-
       vides an  effective way for reviewing the ses-
       sions later.
    •   Have clear objectives and a written agenda to
        keep the sessions on track and to ensure that
        all important topics are covered.
    •   Select a relaxed setting with an informal for-
        mat. Community halls, church halls or local
        meeting places  all work  well. Refreshments
        help to break the ice.
    •   Keep the session to two hotlrs. While a break
        is generally unnecessary, a  short one can
        sometimes  help reorient  the discussion  if
        people are tending to pursue extraneous mat*
        ten  and offers a natural opportunity to shift
        gears and review issues in a different way.
    •   Remain at  the  location  for some time after
        the session. Remember discussions of impor-
        tant or controversial topics  can influence
        people after they leave the session. So atten-
        tion to informal opportunities for discussion
        can  alter impacts and ease anxieties.

    These ideas are based solely on our experiences
and not the  result of a systematic formal evaluation.
Nonetheless, they  are  generally consistent with the
principles found in marketing applications.

    Our experience suggests  that focus groups can
be valuable tools in making risk communication more
effective. They  provide  an opportunity to  listen to
the everyday language people use to discuss risks, as
well as to observe people using  probability  informa-
tion. This  is just the beginning of the new uses of
focus groups in risk communication and related stud-
ies. As more and varied objectives are tried, we will
learn  more about what works and what does not in
communicating risks. We may also find new commu-
nicating ideas as  focus  groups  are used in related
areas—e.g^ the  theory and practice of health educa-
tion. The most important issue  for risk communica-
tors is how to use the technique effectively. To pro-
vide an adequate answer more research is needed.
    Fruitful areas for future risk-communication re-
search include applying focus groups to new  facets of
risk communication (e.g..  new  risks such as  those
from biotechnology), as well as finding more system-
atic ways of getting people to .reveal how they pro-
cess risk information. Interactive research combining
focus groups with laboratory experiments and sur-
veys offers the prospective for providing the needed

                                                                                    Desvousges and Smith
insights.  Clearly, there is a need for more research
findings on how to. organize and  conduct the groups!
    Although focus groups can  DC a valuable  risk-
conununicauon  tool, they are not  a substitute for
more systematic quantitative  research.  They cannot
provide valid statistical results that can be general-
ized to a target population. Because they  are inher-
ently qualitative,  focus group findings need to be
buttressed with carefully executed quantitative analy-
sis from either laboratory or field (survey) research.
Nonetheless, they can  be effective  complements to
more quantitative research'methods.  Focus  groups
improve the quality of information  ultimately ac-
quired in surveys: suggest hypotheses for testing with
those data; and. equally important, provide a wealth
of insights (and anecdotes) that can vividly illustrate
the findings from the quantitative results.

                    June 1989
                    Caron Chess
                  Associate Director

                   Billie Jo Hance
                 Research Associate

                 Peter M. Sandman
     Environmental Communication Research Program
     A Program of the Agricultural Experiment Station
            Cook College, Rutgers University
                  122 Ryders Lane
              New Brunswick, NJ 08903

                        NOTE TO READERS
      Although we have received comments from a number of reviewers, we
would like feedback from those who actually use this workbook to plan their
communication with the public.  The comments of both reviewers and users will
guide the development of another draft of this workbook.

      After you have used the workbook, we would appreciate your taking some
time to fill out the accompanying questionnaire and send it back to us at the
Environmental Communication Research Program (ECRP), 122  Ryders Lane,
Cook College, Rutgers University, New Brunswick, NJ 08903. If your copy is not
accompanied by a questionnaire, please contact ECRP at (201) 932-8795 and we
wfll send you one.  Or you may simply send us your comments. Either way, we
thank you for your feedback.
      Copyright 01989 by Caron Chess, Bfllie Jo Hance, Peter M. Sandman and
the Environmental Communication Research Program.  Permission is hereby
granted for government agencies to reproduce this document, for internal use
only, provided that all copies made incorporate the complete document, including
this notice. For other than internal use by government agencies or to reproduce
portions of this document, write or call the authors for permission at the
Environmental Communication Research Program, 122 Ryders Lane, Cook
College, Rutgers University, New Brunswick, NJ 08903. (201)932-8795.
      We would like to thank the Division of Science and Research, New Jersey
Department of Environmental Protection, which funded the preparation of this







        A. Questions to help identify key
           audiences                                      _.

        B. List of potential audiences


        A. Questions for agencies to raise when
           identifying concerns

        B. Questions audiences may ask of you




        A. Assessing the climate

        B. Things to do before meeting




   As agency staff look toward improving
 their communication with those outside the
 agency,  they often ask for step-by-step
 instructions to guide them through the pro-
 cess. Although experienced communicators
 often follow their intuition, those  with less
 experience want and deserve a more system-
 atic approach.

   Agencies do not have the luxury of allow-
 ing only staff with years of experience to com-
 municate. In fact, technical and policy staff
 who have little communication training or
 experience often need to serve as spokespeo-
 ple because of their knowledge of the techni-
 cal and policy aspects of complex environ-
 mental problems. Communication specialists
 can help formulate policy, coach  from the
 wings,  act as liaisons, and train other  staff,
 but they cannot replace the important inter-
 change between "the experts" and the public.

   While some people  are "born communica-
 tors," others can be made. This workbook
 assumes that a key to effective communica-
 tion is effective planning. Even those with
 extensive communication experience may
 improve their communication efforts  by
 improved planning. The hope  is to replace
 last-minute, poorly conceived communication
 efforts with thoughtful ones. In essence, this
 workbook makes explicit the thinking which
 communication professionals use when devel-
 oping programs.

   Improving Dialogue with Communities:
A   Risk  Communication  Manual  for
 Government  (and the shorter overview,
 "Improving Dialogue with Communities:  A
 Short   Guide  for  Government   Risk
 Communication") laid out a framework  for
 understanding how communities perceive
 risk. The manual argued that  agency  effec-
 tiveness will increase  and unwarranted ten-
 sion with communities will decrease  when
 agencies listen to concerned publics.

   This workbook, which was developed with
 funds provided by the Division of Science and
 Research,  New Jersey  Department  of
 Environmental Protection, suggests how
 agency staff eg" apply guidelines introduced
 in the  manual and short guide. While the
 manual suggests why two-way communica-
 tion is essential to explaining risk, this work-
 book gives more detail on how to promote
 such dialogue. An understanding of risk com-
 munication principles explained in the manu-
 al (or short guide) is essential  for using this

   The manual, short guide, and additional
v copies of this workbook are available from the
 Environmental Communication Research
 Program, Rutgers University,  Cook College,
 122 Ryders  Lane, New  Brunswick, New
 Jersey 08903.
 Why Plan?

    Although agencies understand the need to
 develop sampling plans, risk management
 options, and timelines for policy proposals,
 communication planning is too often over-
 looked. The result is  resource-intensive
 attempts to put out communication fires that
 might have been averted'through effective

    There's not enough time" is the most com-
 mon reason for skipping the planning stage.
 In fact, ad-hoc communication efforts often
 take far more time than carefully planned
 ones. Staff will often find themselves playing
 "catch-up," developing informational materi-
 als and holding meetings that  might have
 been unnecessary if planning had occurred.
 Just as scientific sampling without planning
 can slow down an assessment due to the need
 to rethink and resample, it is ultimately more
 wasteful and time-consuming to develop a
 brochure  or  fact sheet without thinking
 through how it will further your communica-
 tion goals. Meaningful planning can help

      • integrate communication efforts with
        agency risk assessment and manage-
      • increase the effectiveness of communica-
        tion programs;
      • allocate appropriate resources to commu-
        nication efforts;
      • increase dialogue and reduce unwarrant-
        ed tension with those outside the. agency.

How to Use This Workbook

   Before beginning this  workbook it is
essential that you read Improving Dialogue
with Communities in the form of the manual
or short guide. As explained  previously, an
                   basics of risk communi-
cation is essential to using this workbook.

   This workbook is divided into sections that
help you develop different pieces of a commu-
nication plan. While it might be tempting to
work through a specific section of this work-
book when you feel the need for it, this type
of piecemeal planning should be avoided. You
are far better off reading the chapter on the
planning process and methodically working
through all the sections. Then you can go
back and revise particular sections as needed.

   You may want to photocopy sheets of the
workbook before you use them so you can use
the workbook- again for your  next planning
effort. It may be easiest to complete the sec-
tions of the workbook in planning meetings.
Or you may find it easier to assign someone
to complete the workbook and then present
the completed sections for discussion with.
other staff. Regardless, it is critical that all
the staff who are involved in the project
understand and accept the communication
plan. The completed workbook gives you the
outline of a plan, which you can then develop
into the form of a memo, if needed. (See "The
Planning Process.")

   The first time you use the workbook it
may take a while to complete. However, the
planning process should go  more quickly as
you become familiar with it.
A Find Note

   Developing an effective plan is an impor-
tant first step. But turning a plan into reality
binges on factors other than the effectiveness
of the plan. Involvement, support,  and
encouragement of agency management is
critical to ensure that communication plan-
ning  is integrated into agency practice.
Managers may want to refer to "Encouraging
Effective Risk Communication in Government:
Suggestions for Agency Management," avail-
able from th«* Environmental  Communication
Research Program.

   No matter how small your communication
 effort, planning can help. Experienced com-
 municators consciously think through their
 goals before they pick up a phone or write
 even a brief memo. They know that fore-
 thought ran save them a great deal of time.
 When time is particularly tight, communica-
 tion professionals know that planning is par*
 ticularly important; they plan how to cut cor-
 ners rather than cutting out planning.

   Despite their emphasis on planning,
 skilled communicators are not slaves to elab-
 orate plans with intricate timelines. Effective
 communication is often situational, requiring
 both sensitivity and flexibility. But having a
 road map makes it  easier to take  detours.
 Without such a guide, you may spend a lot of
 effort and still fail to reach your goal.
 Planning can also increase your sensitivity by
 helping you think through audience concerns
 ahead of time.
When to Plan

   If you fail to plan your efforts until you
run into problems, you then spend time try-
ing to overcome obstacles that might have
been averted. Consequently, planning seems
difficult and time-consuming. Instead, it's
easier to plan before you begin your commu-
nication effort.

   Because communication should comple-
ment agency scientific, risk management,
and regulatory efforts, planning for your com-
munication effort should be integrated with
project planning rather than  started after a
project has gotten off the ground. For exam-
 §le, NJDEP's Bureau of Water Quality
 tandards and Analysis planned ways to
solicit input from those outside the agency
before drafting regulations. Development of
the communication timeline went hand in
hand with the timeline for drafting of regula-
Who Should Plan

   In order for communication plans to mesh
with agency efforts, communication planning
must involve project staff other than those
who will be involved in the communication
effort. For example, planning for development
of a brochure should have input not only of
the person writing the brochure but also of
those involved in the effort the brochure
describes. Because the public often needs to
hear from "the  experts ," the experts need to
plan for that interaction. Therefore, although
planning may  be easier if communication
staff can help, technical staff are essential to
              planning.           •
   Experience suggests that some of the best
communication plans come from a team effort
involving staff with differing perspectives. In
fact, public relations firms usually hold
brainstorming sessions to spark planning
ideas. On the other hand, writing plans by
committee can be very time-consuming. You
might want to try assigning one person to
coordinate development of a plan with input
of other staff. Or you may want to develop a
planning team which assigns responsibility to
staff for different sections of this workbook.
Regardless, developing a consensus about the
communication plan will be important to
effective implementation.
Planning Steps

   This workbook is divided into chapters
which represent different steps in the plan-
ning process. If you move through the work-
book completing each chapter in sequence,
you should have a comprehensive plan at the

   Determining Your Goals:  Clarifying your
communication goals should help clarify how
to get there. This chapter suggests a variety
of goals that may shape your plans.

   Overcoming Communication Constraints:
The best way to overcome communication
problems is to anticipate them before they
happen and figure out ways to avert or mini-
mize them. This checklist suggests potential
communication problems and ways to over-
come them.

   Identifying Audiences: Before deciding
what to say, you need to think through to
whom you will be saying it. Identifying those
people who may want to have input into
agency efforts may be a key variable in devel-
oping your plans.

   Identifying Audience Concerns: Successful
communication often hinges on knowing what
your audience's concerns are. Although you
will want to talk with people about issues
that are important to the agency, effective
two-way communication will be determined
by whether you communicate about what is
important to your audience.

   Designing Tour Message:  Deciding what
to say is often easiest when you have
addressed your goals, audiences, and audi-
ence concerns.  After completing this chapter,
you will have the basics of a working commu-
nication plan, and the following chapters will
help you structure your approach.

   Methods of Reaching People:  Once you
have determined your goals, the audiences
you want to reach,  and what their concerns
might be, you can think through ways to
reach them. This chapter suggests both tradi-
tional and innovative ways to communi-
cate—including approaches to increase your
interaction with the public.

   Preparing for Meetings with the Public: If
your communication plan includes meetings
with those outside the agency, reviewing this
checklist should help make sure you cover the
important bases, from logistics to process con-

   Planning for Evaluation:  This checklist
can help you plan  to get feedback on your
communication efforts so you can make mid-
course corrections, if necessary.
   Developing Timelines:  Once you know
what you want to do, it is critical to plan
when you are going to do it. A well-developed
timeline can help keep your plan on course.
Developing a Planning Document

   After you have completed these chapters,
it should be relatively easy to draft a formal
communication plan. You might want to write
a memo organized by headings similar to the
chapters of this workbook, based on your
responses to the checklists. This memo,
including a timeline, can then be reviewed to
ensure that it reflects the views of those
involved in the project It can also be a useful
document for discussions with  agency
managers. Just as important, a comprehen-
sive, well-articulated plan may help solicit

   Although planning documents are often
filed and forgotten, your responses to the
checklists and your timeline can be essential
tools to keep your communication effort on
track.  When problems come up, it may be
useful to go back to your checklist of goals to
help sort out possible options. The timeline
should guide the efforts of all the staff who
are involved. Hopefully, instead of "reinvent-
ing the wheel" at various stages in the com-
munication effort, the plan will help you
move forward with assurance.

   The overarching goal of just about every
agency program is to protect the environment
by coping appropriately with the environmen-
tal problem under consideration.

   But the communication goals of a program
can  vary considerably. And achieving the
agency's overarching environmental goal
often depends in large part on specifying and
achieving its communication goals.

   Often agency staff launch a communica-
tion effort without thinking through their
communication  goals—sometimes without
quite realizing that they should have commu-
nication goals. Even t^** simplest communi-
cation activity, such as a telephone call to a
citizen leader, is ideally aimed at a specific
goal Yet one agency representative recalled
that his sole goal  for a particular public
meeting was "to survive." Without clear com-
munication goals, unfortunately, agency
spokespeople can hope to do little better than
survive. Setting more specific communication
goals can lead to a more successful (and less
stressful) interaction with the community,
and  thus can help achieve program goals as

   Hie purpose of this checklist is to help you
       through which communication goals
are most important to the particular program
at hand before you begin your detailed plan-

   The checklist  is subdivided into four cate-
gories: informational goals, organizational
goals,  legally mandated goals, and process
goals. As you go through the list, it may help
to put a "1" next to those goals that are top
priorities for this particular program. Put a
"2" next to the goals of moderate priority.  If
you have goals in mind that are not listed,
space is provided to add them.

   The checklist will be most useful if you
identify no more than four top-priority
goals and  four second-priority goals. You do
not necessarily need to choose a goal in every
category. However, it will help to remember
that agency staff often tend to underestimate
the  importance of process  goals. (See
Improving Dialogue with Communities.)

   Because consensus on goals is essential to
developing an effective communication effort,
you may find it helpful to work through the
checklist jointly with other staff in your pro-
gram, or to compare answers after you have
worked it  through separately. You may also
want to check that your sense of the pro-
gram's goals coincides with your supervisor's

  " Once you have determined your goals,
they can become a key to your planning pro-
cess.  At each stage of the program, you can
look back over your list of goals to see if there
are any you may have neglected and need to
give more  attention. You can "test" each pro-
posed communication activity against your
list of goals, asking yourself whether that
activity will help achieve  the goals  you have
set. You may also want to reconsider from
time  to time whether your choice of goals
should change as the program develops.
Informational Goals

__  Tb give people the data they need to understand better the extent of the risk.

	  Tb tell people what the agency has done, is doing, and plans to do about the problem, and
       what it cannot do, and why.

	  Tb answer questions that have arisen and respond to concerns in the community.

	  Other	;	

Organizational Goals                                      :
_	  Tb build and maintain the credibility of the agency in the minds of all affected publics.
   ..-   Tb coordinate actions within the agency and with other agencies so the governmental
       response is consistent and effective.
  ._    Tb maintain agency efficiency by avoiding unnecessary conflicts with the public.
	  Other:        	;	    ,  •  .        	;

Legally Mandated Goals
_____  Tb provide appropriate advance notice and an appropriate process for public input and
       agency response.
Process Goals
 -.      Tb involve affected parties as early as possible. (See checklist of potential audiences in
       Chapter V.)
 •  _    Tb provide maximum opportunities for public input, including where appropriate a chance
       to help Tialfp and curry out key decisions.
___  Tb keep people routinely informed throughout the process, so they do not feel abandoned
       and do not lose their sense of what the agency is doing.
_____  Tb make only promises that can be kept, and to keep the promises that are made.
_____  Tb build a relationship with the community that is personal as well as bureaucratic, that
       incorporates feelings as well as data.
	  Other	.	•	   •     	

   Hie best way to reduce major problems in
 a communication effort is to anticipate them
 and find ways to avoid them. In general, it is
 far easier to plan for a problem than to con*
 front it as an emergency that can derail your
           tion effort.
   Below are some of the areas that may pose
obstacles and some potential ways to over-
come them. They are not meant to be all-
inclusive but rather to trigger your thinking.
Check the problem, then the solutions you
plan to try.

   Communicating with those outside the agency who are affected by agency decisions may •
 determine whether the decisions are implemented or become mired in  controversy. Despite
 this, agencies rarely allocate sufficient resources to communication efforts.

 Potential constraints

 	  Insufficient staff.
 	  Insufficient funding for printing, subcontracting, etc.
 	; .Other	;	j	;	

 Potential solutions

 _____  Plan more rather tha« less. (Rushed planning will often result in increased implementa-
       tion time.)
 _____  Set clear goals and priorities. (It is far easier to decide how to reduce your effort when
       you are very clear on where you want to go.)
 	  Plan development of written materials in advance, rather than at the last minute, so
       that key pieces of literature can serve several functions.
 ___  Train technical staff so that some aspects of communication can be integrated into their
       day-to-day work.
 ____  Involve leaders of your key audiences in outreach efforts to their members.
 _____  In extreme situations, consider borrowing staff from other efforts.
    ..   Remind management: A communication effort in time saves nine. Proactive attempts to
       communicate are usually less labor-intensive than putting out communication fires.
   Although the agency may feel that there is insufficient time to communicate with people or
to involve them in decision-making, failure to communicate may, in fact, delay your efforts
even further.

Potential constraints

_	  Pressure from inside or outside the agency to act quickly.
	  Mandated deadlines.

       Extended timelines needed for outreach.
Potential solutions

	  Flan communication efforts early so they c?" be integrated into agency timelines. (For
       example, it is easier to involve the public in decision-making if the involvement happens
       •as part of rather .than after the agency's process. See Chapter XI.)
   _    Use short cuts, if necessary. (For example, speak with the leadership of organizations by
       telephone when there is insufficient time to meet with their constituency.)
     -  Use agency "down time" for communication efforts. (For example, work on communica-
       tion while proposals are moving through the approval process.)
	  Develop streamlined processes within the agency. (For example, instead of redrafting
       materials many times, involve key people in planning the materials. Consider conduct-
       ing editing meetings rather than circulating and recirculating drafts, etc.)
	  Plan for informal, smaller-scale outreach efforts rather than large-scale events that need
       a great deal of lead time.
	  Investigate desk-top publishing and other methods to speed production of materials.
	  Recycle your efforts. (Keeping organized lists of contacts, files of materials, and records
       of past efforts can speed your work tremendously.)

   Legal concerns can be a constraint but can also be a convenient excuse for failing to commu-
nicate. Agencies too often use legal problems as barriers to bide behind, causing more prob-
lems than they solve.

Potential constraints

 .-     Confidentiality.
___  Unwieldy procedures.
Potential solutions

	  Examine statutory language rather than assuming the barriers exist!
_____  Explain your plans and ask legal staff for help to overcome any potential legal problems,
       rather than asking whether there are barriers. (This may result in a very different
       response than a question posed essentially as "We can't do this, can we?")
	  Incorporate legal requirements (such as notification, public hearings, etc.) into commu-
       nication planning.

       Be dear with your audiences from the outset about your legal constraints.
       Other	'	
Management Support
   Hie success of a communication effort, as with any other effort, can hinge on support from
those above you.            -      •
Potential constraints
	  Failure to approve or support communication plans and materials. Or delays in approval
       that reduce the effectiveness of your effort.
	  Failure to respond to public input
__  Public statements that contradict the communication program.                              I
	  Failure to allocate sufficient resources.
___  Lip service to communication that is not accompanied by a commitment to recruit, train,
       and reward staff for ffttnmnnjj fating skill.
	__  Other	•     	

Potential solutions
-—^_  Develop well-articulated plans, with rationales in terms that management can respond
_     Document community feedback. (See Chapter X, "Planning for Evaluation.")
___  Build models of success to point to.
.___  Build alliances within and without the agency.
Attitudes of Those Outside the Agency
   Agencies sometimes are concerned that those outside the agency, determined to stir up con-
flict, will "sabotage" any communication effort. Or agency staff may feel that nothing they say
will be listened to.
Potential constraints
  	 Political agendas.
	 Lack of knowledge about environmental issues, risk, etc.
^__ Demands for certainty.
	 Failure to appreciate limitations of resources, science, etc.
	 Hidden agendas.

Potential solutions
   This problem is covered in more depth in Improving Dialogue with Communities.
_____  Involve people in decision-making. (It is particularly important to involve those who are
       most likely to be angry or invested. See Chapter V, Identifying Audiences.")
_____  Listen to those outside the  agency.
	  Give people background on the issues so they can understand.
	  Be forthright.
	1  Other	'	

   The success of a communication effort can
 hinge on early identification of audiences to
 reach. Although it may be tempting for agen-
 cies to aim for communicating with "everyone,"
 communication efforts that nip* too broadly
 may not reach key people. Communicating with
 everyone is a near impossibility. Reaching key
 audiences can save you a great deal of time and
 resources that might otherwise be diffused by
 trying to communicate with the elusive "gener-
 al public,1*

   Because of the potential controversy sur-
 rounding many environmental health issues,
 identifying audiences is particularly impor-
 tant For an agency, audiences are not just
 people who might want  to hear what you
 want to say;  they are also people who want
 to tell you things.  People tend to resent deci-
 sions that are  made without their input. In
 fact, making  decisions for people will virtual-
 ly guarantee their opposition. In addition,
 getting input from outside the agency can
 sometimes help solve complex environmental
 problems. Because agencies cannot get input
 from everybody about everything, careful
 identification of audiences can ensure that
 the agency is listening to those most likely to
 be interested. Just as important, careful
 audience identification reduces the possibility
 of anger at the agency for failing to involve
 people in the decision-making process. (For
 guidelines  about dealing with different audi-
 ences see Chapter IV in Improving Dialogue
 with Communities.)

   Identifying audiences is largely a process
of thinking through as specifically as possible
who should be involved in a dialogue with the
 agency. The following steps may be helpful:

 L Answer the questions listed in the follow-
   ing section  "Questions to Help Identify
   Key Audiences." They  might trigger your
   thinking of additional questions tied to the
   issue with which you are grappling.

2. Talk with others in the agency who have
   dealt with similar issues or review records
   of public hearings about related concerns
   for ideas about interested audiences.

3. Review the list of potential audiences that
   follows  the list of questions. Select the
   audiences that  are appropriate to the

4. Determine which audiences are most
   important for you to communicate with.
   Often the audiences that are most dif-
   ficult to deal with—and the ones you
   might be hoping to avoid—are  the
   ones you most need to  communicate
   with. It may help to prioritize your audi-
   ences by dividing them into three cate-

      a. The inner circle—those most like-
      ly to be very concerned and very
      interested.  They must  be contacted
      and involved to the greatest extent
      possible. To a certain degree this cir-
      cle is self-selecting. If people want to
      be very involved, they should be very

      b. The middle circle—those who have
      less concern or are more peripheral
      but are apt to be upset if not contact-
      ed They should be contacted, invited
      to be involved, and kept informed.
      This group is also self-selecting to a
      certain extent. People decide for
      themselves if they want to make the
      commitment  of the middle circle to
      occasional  input  and  progress

      c. The outer circle—those who are
      less likely to be concerned. This often
      includes the "general public."  Less
      effort should be directed to these
      audiences than the other two, and
      the effort should be aimed .at involv-
    .  ing them in the middle circle.

5. As you  contact people, ask them if they
   know of others you should be contacting.

   The Mowing questions may help identify
 audiences for you to reach among those sug-
 gested on the "List of Potential Audiences,"
 which follows. There is room under each ques-
 tion for you to list audiences that are impor-
 tant for you to deal with. Those groups that
 are relevant to  more than one question are
 particularly critical for you to reach. Although
 you may feel like avoiding groups  or individu-
als who may be difficult to deal with, these
are often the most likely to raise issues if they
are not consulted early. In fact, if you would
prefer not to hold a dialogue with a group
because it is hostile or otherwise problematic,
that group should be at the top of your list to
contact. Otherwise, your effort will be even
more vulnerable to criticism because you have
failed to address that group's concerns.
   Which groups have been previously involved in this issue? (Newspaper clippings, discus-
   sions with other staff in the agency, and transcripts of public meetings can help with find-
   ing this out.)
2. Which groups are likely to be affected directly by the agency's policy, regulation, or
3. Which groups are likely to be angry if they are not consulted with or alerted to the issue?
4. Which groups would be helpful for you to consult with because they might have important
   information, ideas, or opinions?
5. Which groups should you involve to ensure that the  agency has communicated with a
   balanced range of opinion on the issue?
6. Which groups may not especially want input, but do need to know what the agency is


   The following list is meant to trigger your
thinking rather than to be exhaustive. As you
go through the list, it may help to put a "1"
next to those audiences that are top priorities
for this particular program. Put a "2" next to
audiences of lesser priority. Use the  lines on
the right to fill in names.

   _   Your division

	  Other divisions
       Other federal, state or
       local agencies	
       County agencies
       Municipal agencies.
       Federal, state, or local
       elected officials	
       Legislative committees
       Quasi-governmental agencies overseeing specific functions
        _  sewerage authorities	;	
       __ regional planning commissions.
       ___ environmental
       Emergency responders.

Geographical Neighbors

	  Local residents	
       Local businesses


	 National groups.
       State-wide groups,

       Local groups;	

       Groups related to specific issues:
       J	Siting
       _:	Hiking  .
       __^ Watersheds                     _
       ___ Natural features (e.g. swamps, lakes, oceans,
           forests, etc.)
       _ Other
       Groups with specific functions:
       	Lobbying __
       	Research _
       Other types of environmental organizations:
Civic Organizations
	  League of Women Voters,
       Associations such as Kiwanis,
       Rotary, etc. ____________
       Associations of senior citizens

       Ethnic groups
       Other organizations or individuals who have stature in the community and influence
Professional and Trade Associations
   It is particularly important to reach those industries and occupations that
     1) might benefit from an action;
     2) might "lose* from an action;
     3) have relevant expertise; or
     4) will be important to secure cooperation during the implementation phase.
       	Health officers                                         ...
       	Doctors	:	
       	Nurses „	

       __ Water purveyors
       ___ Consultants   .
       	Planners _____
      __ Chambers of Commerce.
      	Industrial groups	
      Other trade-related:.
Educational and Academic Organizations
	 Colleges	;	
      Public and private schools

      Other	'
Religious Organizations
Other Organizations


    Unless you have a great deal of familiarity
 with the issue and the audiences involved,
  ou can create misunderstandings by assum-
    l you know people's concerns—or by
 assuming they are  the same as yours. Thus,
 identifying people's  concerns before you speak
 with them will greatly reduce communication
 frustration.'Because different constituencies
 have different concerns, it is crucial to deal
 with key audiences when identifying con-

    listed below are some ways of identifying
 audience concerns. With the  exception of
 polls, these  approaches will not yield statisti-
 cally significant data. They will, however,
 provide you with a snapshot of people's con-
 cerns. Because they may not give you the full
 picture, the approaches below should be seen
 as preliminary assessments rather than final
 analyses. If you use two or more of these
 approaches, and the information seems con-
 sistent, your "snapshot" is more likely to be
 an accurate reflection of  the full picture. If
 the information conflicts,  you should ideally
 keep investigating.  You can feel fairly secure
 that you understand audience concerns when
.you no longer identify new ones.
                                              "Before identifying audience concerns it
                                            may be helpful to imagine what those con-
                                            cerns might be. Although this is no substitute
                                            for asking, it may be a useful first step to ori-
                                            ent your thinking.

                                               Taking one of the approaches listed below
                                            is better than none. Taking several is better
                                            still. The more potential for controversy, the
                                            greater the number^ of these approaches you
                                            might want to take^ (Those marked with **"
                                            are described  in more detail in the report
                                            Evaluating Risk Communication Programs: A
                                            Catalogue of "Quick  and Easy" Feedback
                                            Methods, by Mark Kline, Caron Chess, and
                                            Peter  M. Sandman  of the Environmental
                                            Communication Research Program, Rutgers
                                            University. This report is available from  the
                                            Environmental Communication Research
                                               You may want to number the approaches
                                            you intend to take in the order in which you
                                            intend to take them  and note the date by
                                            which you hope to accomplish each task This
                                            information can then be used to develop your
                                            timeline. (See Chapter XI,  "Developing
      Review newspaper clippings about the issue. *
      (This is a good way to get a quick overview.)

      Discuss audience concerns with other agency officials (perhaps including those in other
      states) who have dealt with similar issues.
      (This can give you a sense of the concerns that have arisen in similar situations.)

      Meet informally with those interested in the issue.
      (Informal meetings or telephone contacts can give you a first-hand idea of both substantive
      concerns and the feelings about those concerns.)

      Send a letter to potentially interested people and organizations asking them to send you a
      list of their questions and concerns. *
      (This «•*»" be a very useful way to initiate a dialogue that involves a greater number of peo-

      Develop a survey (which you can give to people through a door-to-door effort, at meetings.
      or in mailings) that asks people about their questions and concerns. *
      (This more formal approach must be developed with care so that people feel they can artic-
      ulate their concerns, not merely respond to yours.)

Brainstorm questions and concerns at the beginning of a meeting. Or ask people to write
their questions on index cards that you distribute and collect.
(Often you will want to know people's concerns in advance of a meeting, but this approach
can be very useful for ensuring that you meet your audience's concerns and for showing the
audience that you are doing so.)

Brainstorm questions and concerns at the end of a meeting. Or hand out index cards at the
end of the meeting in, preparation forlhe next
(The audience  may not be the same people, but this is still a good tool where there are con-
tinuing contacts.)
Date:	'

Consult advisory committees.
(In order to be useful advisory committees must be representative of the audience you will
be t?fannniT"gating with.)

Conduct a poll *
(Polls are useful to obtain a little bit of information from many people. They are less useful
to obtain in-depth or qualitative  information about people's concerns.)   ,                      [
Date:	                                                                1

Conduct a focus group. *                                                                  ,
(Focus groups are informal meetings of people representative of your audience. The groups,      (
which are guided by a trained moderator, are used to elicit attitudes, ideas and feedback.)



   Now that you have identified some ways
to solicit the concerns of your audience, this
checklist suggests questions you might raise
during this process.

   The following questions are meant to be
generic ones that probe topics that are usual-
ly of concern to people. You will probably
want to adapt and build on these questions to
suit the situation with which you are dealing.
In fact, some of the questions below might
lead you to ask a series of more specific ques-
tions. For example, the question concerning
the type of interaction people would like to
have with the agency could raise the issue of
how often people would like to have meetings
and of what sort

   In some  cases you will want to ask about
most of these topics. In others, one or two topics
will be of primary concern. Place a "1" by those
questions that you feel are most critical to ask
and place a "2" by those of secondary impor-
       What type of interaction would you like to have with the agency?

       How do you feel about your interaction with the agency thus far?

       What questions do you want answered?

       What kind of technical information (scientific studies, etc.) do you want to know?

       Do you have comments and suggestions that you want to put on the record? What sort of
       response, if any, will you want from the agency?

       What objections do you have?

       What else can you tell me that will help the agency be more responsive to your concerns?

   It is problematic to generalize about the
kinds of questions people may raise to agen-
cies because they vary from situation to situ-
ation. Questions raised by an advisory group
to development of regulations will differ
greatly from those of people living near a
Superfund site. Because agencies tend to
have a great deal of difficulty anticipating the
concerns of those who are potentially exposed
to an environmental contaminant, the follow-
ing list suggests some of the questions specif-
ic to such situations.
   In general, the types of concerns people will
have over such an issue will fall into four cate-
  (a) Health and lifestyle concerns (How will this
     affect me/my family?);
  (b) Data and information concerns (What is this
  (c) Process concerns (How am I being treated?);
  (d) Risk management concerns (What is the agen-
     cy going to do about this?).
   All four types of questions may be repre-
sented in any one community.

   The following checklist represents some
common concerns you might expect to hear
when you ask  the questions in the previous
checklist We provide it to familiarize you
with the types of community concerns
you may face, not as a substitute for iden-
tifying the community's concerns. We can-
not overemphasize that each situation is differ-
ent and each community has its own set of spe-
cific concerns. Indeed, each individual within a
community has his or her own concerns.

   It may be helpful for you to check off these
questions you  anticipate. You may  want to
review the list again after you have contacted
communities about their concerns.  Finally,
this checklist should be referred to when you
are determining the  content of materials or
presentations. (See Chapter VII.)
Health and Lifestyle Concerns

	  What is the danger to my health and that of my family?

 -      Can I drink the water, eat the vegetables in my garden, etc.?

	  What can I do to find out if my health has been affected?

	  What can I do to reduce the damage already done?

	  What can I do to prevent further damage?

	  What about my children? (Concerns about children are often primary and quite spe-
       cific about the implications of exposure and whether certain behaviors will increase
       their risk.)

	  We are already at risk because of X. Will Y increase our risk?

	  How will this affect our quality of life—property values, the stigma of X attached to
       our community, trucks on our local roads, etc.?
       How will we be protected in an accident?

       How will we be compensated for the loss of value of our homes?

       Other _	.

 Data and information Concerns
 	  How sure are you?
    __  What is the worst case scenario?
 	  What do these numbers mean and how did you get them?
 	  HOW do we know your studies are correct?
 __  What about other opinions on this issue?
 __  How do our exposures compare to the standards?
 	  You say X can't happen. Why not?
 '	  Other		•	
Process Concerns
   Although agencies tend to focus on data, communities may be very concerned with
issues other than the data. (See Chapter I of Improving Dialogue with Communities.)
	 How will we be involved in decision-making?
   .   How will you communicate with us?
	 Why should we trust you?
	 How and when can we reach you?
	 Who else are you talking with?
	 When will we hear from you?
	 Other 	_
Risk Management Concerns
   Concerns about how the risk will be handled are often more important to people than
details about the data.
____ When will the problem be corrected?
    •  Why did you let this happen and what are you going to do about it?

What are the other options? Why do you favor option X?
Why are you moving so slowly to correct the problem?
What other agencies are involved and in what roles?
What kind of oversight will we have?

   Whether you axe making a presentation at
 a formal public hearing, writing material for
 a handout or a brochure, or simply talking
' informally with a group of homeowners, you
 will want to do some thinking about what you
 will say and how you will say it. Much of
 what you do say will depend on the informa-
 tional, organizational, legally mandated, and
 process goals you have outlined. (See Chapter
 in, •Determining Your Goals.")

   Whether written or spoken,  presentations
 that  consider  and address audience con-
 cerns—and at the same time cover the rele-
 vant technical information in lay terms—will
 be the most  useful to your audience. Such
 communications are less likely to be thrown
 in the trash because they are too confusing,
 "hooted down" by a frustrated community, or
 met with a barrage of non-technical questions
 that leaves you wondering whether you were
 heard at all.

   The following is some guidance for  devel-
oping the content of your message. The first
 section will help you decide what are'the
most important things to include when you
obviously cannot include everything. The sec-
ond section will help you to fine-tune your

   One word of caution:  If you are giving a
spoken presentation, try not to become so
invested in it that you will become unglued if
in the middle you are required to change gears
slightly. Interactions with the public—particu-
larly those involving controversial environ-
mental issues—require flexibility and the abil-
ity to incorporate the needs of your audience
as much as possible. While you should prepare
thoroughly and put forth your best effort, it is
a far greater and more useful skill to be able to
sense and respond to an audience's immediate
needs if they turn out to be different from
those you anticipated. If you are  writing a
brochure  or other informational piece, make
sure you get feedback from potential audiences
before it is finalized and expect  to make
changes down the road based on feedback you
get after it is released. (See Chapter X,
"Planning for Evaluation.*)
Content * What Your Material Should Cover

   The following categories may help you to define what material you should cover in your

L  List the three items you would most like your audience to learn from your talk or written
2* List the three items you feel your audience wants to learn from you.


3. What three additional background points do you feel your audience needs to know so they
   understand A and B?  '
4. Finally, list the three most likely points your audience will misunderstand or get wrong
   unless you stress them and explain the possible misunderstanding.
Other Things to Consider

   After you have completed the above exercise and decided on the content of your materi-
als, the following checklist may help you in completing your materials or presentation.

___  Look again at your goals (Chapter HI). Does your presentation or materials advance
       them appropriately? Are there any goals you have not addressed and should?

'       Have you put technical terms in language that lay people can understand?

____  Are you using graphics where appropriate to illustrate your points?

	  If you are using graphics, are they dear? Are they simple enough to be useful or clut-
       tered and confusing? If you are using slides or overheads, can they be read from the
       back of a room?

	  Is your presentation/materials too long? Too short?

____  Have you pretested your presentation or materials? (See Chapter X, "Planning for

___  Are there obvious places in your spoken presentation to stop and answer questions?

'       Can you handle the questions that may arise from your talk? If not, have you invited
       the appropriate colleague or other expert to assist you? Have you incorporated into
       your written materials the questions that people are most likely to have?

	  If the material is for a spoken presentation, does it leave room for change? Does it
       summarize at the end?


   The approaches you use to reach people
will vary depending on the  issue and the
audiences. For example, while a pamphlet
might he a very useful approach to inform
those who own wells about new water regula-
tions, it would probably not be as useful to
elicit feedback from them. Nor would it be
satisfactory for those who are directly affect*
ed by the regulations (e.g. industries with
discharge permits), who would need more in-
depth materials.
.   There are no real rules for choosing the
right methods to reach people. But the fist of
options which  follows may help  you think
through a variety of approaches. The type of
approach you use should be determined not
only by what you are most comfortable with
but also by the best  methods for the audi-
ences you are trying to reach. For example,
people who are very angry or frightened may
need the interaction provided  by an informal
meeting as well as an information line they
can call with further questions.  A booklet
about the subject, while possibly a useful
addition, may be less successful in dealing
with  people's emotional concerns. When
choosing the appropriate  methods  of out-
reach, it helps to take into account the follow-
ing factors:

L Resources available.
   (A limited budget will limit your choices.)

2. Lead time to prepare an outreach effort.
   (It helps to develop a realistic timeline. For
   example, a pamphlet will take far more
   time to produce than a letter. Planning an
   informal meeting takes less time than
   forming an advisory committee.)

3. Audience needs.
   (This is a key factor that is often over-
   looked. Although you may want to provide
   people with written data, they may want a

4. Degree of interaction needed.
   (Complexity, emotional distress, and other
   factors may suggest an interactive ques-
   tion-and-answer approach supplemented
   by written materials rather than a one-
   way approach using only written materi-
   als such as fact sheets.)

5. Degree of controversy.
   (The more controversial an  issue, the more
   likely it will require person-to-person
   interaction and input from people outside
   the agency. Controversy also suggests the
   need for small rather than large meetings.
   See Chapter IV of Improving Dialogue
   with Communities.)
6. Distribution.
   (It is critical that you think through how
   you will distribute audio-visual and writ-
   ten  materials before you produce them.
   Similarly, consider your mailing list before
   you plan a mailing.)
7. How much detail needs to be communicated.
   (In general, more detail requires more writ-
8. Legal requirements.
   (There may be legal stipulations about
   timing of notification or agency response
   to public comments.  But do not assume a
   particular approach is le'gally  required
   just because it has become customary in
   the agency.)
   The following methods, which are meant
to trigger your thinking rather than to be
comprehensive, are divided into four cate-
   1) Written or audio-visual communication;
   2) Person-to-person communication;
   3) Communication via the mass media; and
   4) Approaches particularly useful for eliciting
   Approaches marked with "*"  are those
that agencies might want to consider using
more frequently, either because  they tend to
be overlooked or because they can be particu-
larly useful in dealing with controversy.

   It may be helpful to check off your top five
choices for the situation at hand and  discuss
their strengths and weaknesses with other
staff. In many cases, you will want to use more
than one method of reaching people. For exam-
ple,  you may want to talk to some people in
advance of an informal meeting, mail  them a
fact sheet, and have a handout at the meeting.
   The approach you use should vary from
situation to situation. In fact, always relying
on the same approach time after time is prob-
ably missing the same people time after time.
If this is the case, rethink what is new about
the situation at hand and what approaches
are suggested by that uniqueness.

Written or Audio-Visual Materials
__  Pamphlets
   ..._.  Legal notices
       (While these fulfill legal obligations, they do not effectively reach many audiences.)
____  Newsletters
__  Periodic updates *            •
       (These are less formal and less work than newsletters.)
"       Articles or announcements in other organizations' newsletters *
       (These can often reach a greater audience than your own materials.)
  -     Displays
	  Fact sheets
	  Curriculum materials
_____  Comics
	  Question-and-answer sheets *
       (These are very useful when they directly address audience concerns.)
 	  Placards in mass transit
	  Inserts sent with utility bills or other mass mailings
	  Slide shows
	..  Audio tapes
	  Other	;	
Person-to-Person Approaches
 ..     Presentations
       __ at your own events or meetings
       __ at others' events or meetings

       Availability sessions or "out-of-office hours" *
       (These give you a chance to talk with people on their turf, meet people who might
       never travel to a meeting, and address people personally.)
       Public hearings
       Informal meetings *
       (These are more useful to create dialogue than public hearings or large meetings.)
       "Open" working meetings
       Open-door days, when agencies are open to the public and events, lectures, discus-
       sions, etc. are scheduled.
       Advisory committees
       Telephone trees
       Information telephone lines
       	Child-focused events
       	Improvement-focused events (e.g. clean-ups)
       ___ Conferences
Mass Media Approaches
   In addition to responding to inquiries from reporters, agencies can initiate contact with
the media and take a pro-active approach to getting the word out.  Do not overlook local
media, such as weekly newspapers, that are often widely read in communities.
	 News conferences
____ News releases
	 Letters to the editor
	( Talk shows
___ Call-in shows *
      (These have potential to create a dialogue.)
_^_ Op-ed columns

       Feature articles
Approaches for Eliciting Input
   All of the following are starred because they encourage the agency to listen to those outside.
_^_  Informal meetings *
 -__   Questionnaires *
	  Advisory groups *
___  Brainstorming *
	  Interactive workshops *
	  Evaluations of agency process*
	  Suggestion boxes *
	  Dividing large meetings into small groups *
^^_  "Dialogue" telephone-lines •

   Many agency practitioners have a fear of
meeting with the public that is based on past
experiences with angry and frustrated com-
munity  members at large public meetings.
There is a general sense that a meeting with
the public is an "anything goes" situation,
and that agency representatives can never
know what is going to happen until they're in
the meeting.
   As .a result of these experiences, agency
people very often brace themselves for the
 battle, their only hope being to "come out
- alive." While the following checklists cannot
 shield you from communities' understandable
 anger over certain situations, they can help
 you (a) do some thinking beforehand about
 why a community may react a certain way;
 (b) see yourself and your agency from the
 community perspective; (c) avoid  angering
 the community unnecessarily; and (d) pre-
 pare to respond to public reaction.

   Before you prepare for the meeting
 (whether it is a large public meeting or a
 small informal gathering), you should consid-
 er the general climate or mood of the commu-
 nity. First, you will want to find out people's
 concerns. (See Chapter VI, "Identifying
 Audience Concerns.") But beyond that, try to
 go one step further .and-assess how their con-
 cerns might affect people's response to you in
 your role as an agency representative.

   The following list of questions might help
 you to better  characterize the climate. (See
 also Chapter IV of Improving Dialogue With
 Communities.) It may be helpful to you to do
 some thinking about these questions and the
 exercise that  follows with a colleague who
 has also been  involved with this situation, to
 compare his or her impressions with yours.

 1. • How are you seen in this situation? What is
   your role and the role of your agency?

 2. What is the history of the situation? Has
   your agency (or have you) been involved pre-
   viously? Favorably or unfavorably?
3. Have community concerns been a factor in
   previous agency decisions regarding this
   issue? How does the community see its role
   in the situation?  Does' the community have
   a role in the decision-making, or is it simply
   being informed of the agency's decision?
4. How great is the interest in the situation?
   Are people angry?  Apathetic? What kind of
   reactions have you seen (or heard about
   from colleagues, contacts, or news coverage)
   up until now?
5. Are there hidden agendas?  Are there elect-
   ed officials or groups that are involved in
   building support over this issue?
6. What kind of media attention has the issue
   received locally, regionally,  and nationally?
   Are there likely to be reporters present at
   fViig meeting?

7. How many people do you think will attend
   the meeting? A large number? Only a few?
   How long do you think the meeting will last?
   Based on the answers to the above questions, try to characterize the type of meeting you
might expect, using the checklist below.
   Choose two terms that you feel will best describe the meeting tone:





	  apathetic, uninterested


   .....   introductory

	  questioning and information-seeking

	  interactive and problem-solving

	  other:	•	

   Regardless of your initial assessment of the
 tone of the meeting, which you have indicated
 on the preceding checklist, you can still have
 an effect on the tone either positively or nega-
 tively. Although you will rarely dramatically
 change its nature, you can shift it somewhat
 For example, it is difficult to turn a controver-
 sial meeting into one-without .conflicts, but you
 can affect the way conflict is handled in a
 meeting, and how angry the meeting gets as a
 result of the conflict

   The major areas for concern when preparing
 for a  meeting with the public include process,
content, logistics, and trouble-shooting (explicit-
ly thinking through potential problems in order
to avoid them). Attention to all of these areas is
important; neglecting to think about any one of
them may lead to a less than favorable outcome.
For example, if you have failed to provide park-
ing at the meeting, or if you have neglected to
invite an interested and affected group, people
may be angry at you even before you give your
well-prepared presentation.

   The following checklists represent many
items under these four headings—you may
think of others.
       Have you talked with affected people ahead of time? (See Chapter VI, "Identifying
       Audience Concerns.")

       Have you done appropriate outreach to see that those who should be there—and who
       want to be there—are invited?

       Have you arranged for appropriate spokespeople (including technical experts, decision-
       makers, and officials of other agencies, if appropriate)?

       Have you chosen an appropriate chairperson? (Think about the implications of a com-
       munity, agency, or neutral person.)

       Have you picked a suitable location for the meeting? (A neutral location may be more
       appropriate than somebody's "turf.")

       Have you developed an agenda that provides a structure for the meeting that is appro-
       priate to deal with both the agency's and the audience's concerns?

       Have you gotten input from your audiences) about the agenda?

       Have you reviewed the timing of the agenda and allotted realistic times for items?

       Have you considered how you will  handle conflict if it arises?

       Have you appointed a notetaker? (Someone should write down promises agency repre-
       sentatives make and follow up on them.)

       Have you made sure documentation (e.g., tape recorder, newsprint, or notetaker) is
       available, if necessary?

       Have you considered how you will  get feedback on the effectiveness of the meeting? (See
      -Chapter X, "Planning for Evaluation.")

       Have you gone over your list of possible questions in advance? Are you prepared to
       respond to them? Or better yet, have you integrated the answers into your presenta-
       tion? (See Chapters VI and VII.)

       Have you prepared background material and handouts?
       Have you gotten feedback on your presentation from someone not involved with the
       Have you gotten feedback on the materials you have developed? (See Chapter X,
                 for Evaluation.")
       Has the agency examined possible actions and policies that respond to people's con-
       cerns? Have these actions been taken or policies adopted?
       Other:    _ ' _ ._ _ " _ '
       Big enough room?
       Right shape for presentation?
       Room temperature controlled?
       Both building and room wheelchair-accessible?
       Directions available to meeting location?
       Convenient location?
       Sufficient parking?
       Signs in building that point to room?
       Appropriate time—i.e., evenings or weekends for working people?
       Childcare available?
       Microphones for speakers and audience?
       Podium or table?
       Enough chairs? Are they arranged?
       Food and beverage available?
       Flip chart and newsprint?
       Markers, rf*aii^ etc.?
       Masking tape and/or push pins to hang newsprint and other visuals on the walls (and
       permission to do so)?
       Audio-visual aids tested and ready? Extra bulb, extension cord, remote control switch,
       Name tags for speakers?
       Sign-in sheet?
       Other:	         .	

   You also might want to do some thinking before the meeting about how you will react and
respond during the meeting. Some things you may want to be prepared for are:
	  Going over the agenda at the beginning of the meeting and, to the extent possible, mak-
       ing changes that people suggest
	  Changing gears in your presentation based on audience reaction.
	  Dealing with outside groups you hadn't invited or counted on.

Being prepared to respond to suggestions, concerns,  requests.
Being prepared to stay after the meeting to answer individual questions.
Handling conflict if it erupts.
Dealing with more people than you expected to attend.
Dealing with fewer people than you expected to attend.
Dealing with someone in the audience who starts giving a speech.
Dealing with people .who monopolize the meeting.
Dealing with the.media.
Other:	:	


   Agency practitioners recognize that improv-
ing their communication requires a conscious
effort to find out more about what is working
and what is not-preferably while there is still
time to change direction as appropriate.  In
fact, feedback is essential to ensure that your
communication effort is working and may save
you time by helping you make mid-course cor-
rections in your plans.  But in practice, evalua-
tion is often neglected in the press of other,
more urgent tasks—especially if it has not been
planned for in advance.
   To make it easier for agency people to elic-
it feedback on  their communication efforts,
the Environmental Communication Research
Program at Rutgers University (funded by
NJDEFs Division of Science and Research)
has written a report that describes "quick
and easy" tools an agency can use to get feed-
back on their communication efforts.  These
"quick and easy" methods are most appropri-
ate for small-scale risk c*?rnTri'''>'n^eat:'0'n efforts
for  which  statistically  reliable,  more
resource-intensive evaluation methods are
not suitable. Agency staff looking for ways to
evaluate their communication work should
consult Evaluating Risk Communication
Programs: A Catalogue Of Quick and Easy"
Feedback Methods,  by Mark Kline,  Caron
Chess, and Peter M. Sandman.
   The checklist that follows is designed to
help you integrate the recommendations of
that report into your communication plan-
ning.  Lake the report itself, the checklist is
divided  into  four  sections,, "Audience
Analysis," "Message Pretesting," "Assessment
of Communicator Style," and "Outcome
Assessment" For each category, check one or
more evaluation tools that seem like they
might be appropriate for your project. Read
the relevant sections of the report to deter-
mine which are actually the most appropri-
ate.  Then indicate when in the communica-
tion process it will be suitable to use each of
the tools you have identified.
   You may well find it difficult to select
appropriate evaluation methods if you have
not read the "Quick and Easy" report. If risk
communication is a small part of your job
(and communication evaluation a smaller
part), you may find it more efficient to seek
advice on which evaluation tools to use from
someone else in the agency who is already
familiar with the report's recommendations.
The first chapter of the report also provides a
brief summary of all  the tools discussed in
detail later. The important thing is to make
sure evaluation is not omitted from your com-
munication planning.
Audience Analysis

	  L  Policy Profiling Questionnaire (to identify stakeholders in an issue and organize agency
       perceptions of them)

	  2.  Audience Analysis Matrices (to identify relevant audiences and organize agency percep-
       tions of their reactions, involvement, or position in a communication effort)

	  3.  Audience Information Needs Assessment (to gather questions from relevant audiences
       in advance of public meetings so a response can be organized and presented)

_^_  4.  Analysis of News Clippings (to identify audiences and their concerns; to develop some
       historical knowledge of a community to help in planning future phases of a communication

_____  5.  Public Opinion Polling (to assess audience opinion or reaction; to find out what people
       see as important problems, what issues and events they are aware of, and how they evalu-
       ate social and political institutions)

_____  6.  Public Opinion Polling/Pollstart (to organize and analyze polling data on personal com-
       puters available within the agency)

       7. Qualitative Questionnaires (to collect information from people whom agencies have          .
       involved in a communication effort)                                                      I
       Other tools	
When will you use each tool?
Message Pretesting

_  L Rightwriter (to review documents written on computer word processing programs for
       errors in grammar, style, usage, and punctuation)
__  2.  Smog Readability Grading Formula (to evaluate the level of reading comprehension
       a person must have to be able to understand a piece of written material)
   ....  3.  Signaled Stopping Technique (to examine how readers process information as they
       read written materials and through this procedure to get feedback on those materials)
   -..    4.  Self-Administered Pretest Questionnaires (to get feedback on pretest materials)
       5.  Central Location Intercept Interviews (to get feedback on pretest materials or to
        amine an audience's attitudes and opinions)

       6, Theater Testing (to get feedback on visually presented pretest materials)

       7. Focus Groups (to get feedback on and generate ideas about pretest items; to get a
       "feel" for the attitudes and beliefs of the target audience)
       Other tools.
When will you use each tool?
Assessment of Communicator Style

	  1. Myers-Briggs Type Indicator (to provide feedback on the communication styles of
       agency staff)
   ..    2. Strength Deployment Inventory (to identify the strengths of agency staff and sug-
       gest ways these strengths can be used to communicate more productively with others)
	  3. Conflict Management Survey (to provide feedback about a respondent's approach to
__	  4. Communication Style Survey (to provide feedback on the respondent's style of inter-
       personal communication)

When will you use each tool?	;	
Outcome Assessment
_.      1* Meeting Reaction Form (to get feedback about participants' reactions to a public
_____  2. Verbal Meeting Feedback (to get direct feedback from participants at a meeting)
_____  3. Speech Evaluation Checklist (to get feedback on how a speech or presentation went)
   -..-   4. Observation and Debriefing (to get feedback on speeches and presentations)
	  Other tools	;	;	

When will you use each tool?   _                                         	


   Most of the checklists and tools in this
workbook are designed to help you figure put
what to do to make your communication
      a success. The essence of a timeline is
to help you decide when each step needs to be

   A timeline is -the key-to getting -from a
mere list of things you hope to accomplish to
a plan  for accomplishing them. The more
thoroughly you work through the other parts
of this workbook, the. more ambitious a com-
munication program you design, the more
need you will  have for a timeline. When an
agency does not use a timeline, key elements
of its communication strategy are likely to be
implemented ineffectively or abandoned
entirely simply because essential preliminary
steps were not taken; by the  time the agency
got around to focusing on  the element in
question, it was too late.

   Using a timeline, in other words, forces
the agency to consider when  it will hold that
meeting with local farmers (for example),
what it  must do to get ready for the meeting
(find a  hall, send  out a mailing, prepare a
handout, discuss a possible agenda with rep-
     tative farmers, etc.), and when it  will
take each of these preliminary steps. Because
the agency used a timeline, the meeting with
farmers is more likely to happen and more
likely to be a good meeting.

   Timelines also serve other purposes in
   1) They facilitate the assignment of tasks to
particular staffers, so everyone's responsibilities
are clear.
   2) They help identify overeommitted periods
(suggesting a need for extra staff, rescheduling, or
some other solution) and slack periods (suggesting
an opportunity for additional communication
efforts and a possible problem if the agency hopes
to maintain momentum).
   3) They make it easier to see gaps in the com-
munication plan—particular audiences that will
not be reached, for example.
   4) They help the agency respond to changing
conditions (adding elements to the  timeline in
response to new concerns, moving elements for*
ward or back in the timeline as needed.

   But their key role is that they clarify what
                                            needs to be done when, and thus make it less
                                           - likely that important deadlines will go unno-
                                            Steps In Building and Using a Simple
                                            L Draw a literal "timeline"—a long line (hori-
                                               zontal or vertical) that represents calendar
                                               time. Start with the current date. Choose
                                               an appropriate ending date—one year later,
                                               tiie next fiscal year, the deadline for com-
                                               pleting the new regulations, etc. Divide the
                                               timeline into months (or weeks if the peri-
                                               od covered is relatively brief).
                                            2. Insert all relevant dates that have already
                                               been determined and cannot be changed,
                                               including those determined by external
                                               forces—the date of a scheduled referen-
                                               dum, for example, or a legally mandated

                                            3. List the major elements in your communi-
                                               cation plan so far—the questionnaire you  .
                                               want to distribute, the groups you intend
                                               to meet  with, the public hearing you must
                                               have, etc. Choose an appropriate date for
                                               each and add it to the timeline.

                                            4. For each element identified in #3, list all
                                               the steps necessary to make sure that ele-
                                               ment is successful. Think about prelimi-
                                               nary contacts with affected audiences,
                                               logistical preparations, substantive prepa-
                                               rations, handouts and other materials,
                                              - liaison  with other programs and other
                                               agencies, pretesting and evaluation, etc.
                                               Do not forget follow-up steps—sending out
                                               the minutes of a meeting, for example, or
                                               calling key people  who could not come. It
                                               will be helpful to involve other staff mem-
                                               bers in  brainstorming these steps  so that
                                               you do not miss any important ones.
                                               Choose  an appropriate date for each step
                                               and add it to the timeline.
                                            5. Now examine the timeline for complete-
                                               ness, feasibility, and efficiency. Is there
                                               anything you ought to be doing that is not
                                               there?  Is there anything there that can-
                                               not be done in  the time allotted with the
                                               resources available? Are there slack peri-
                                               ods when there will be little to be done?
                                               Adjust the timeline as appropriate.

6. If several people are involved in the com-
   munication effort, copy the timeline onto a
   blackboard, poster paper, or some similar-
   ly visible medium, and put it where all
   staff members can see what needs to be
   done. Make sure the medium you use per-
   mits changes.

7. Decide jointly with other affected staff
   members how .the .timeline, will be kept up
   to date—a procedure for adding, abandon-
   ing, and moving items in response  to
   changing conditions. Make sure everyone
   understands that  the timeline is a plan-
   ning tool—it should be neither forgotten
   nor followed slavishly. For example, if it
   becomes clear that a particular step can-
   not be completed on deadline, the staff
   should think through the problem and
   adjust the timeline.
More Complex Timelines
   For complex communication programs, a
simple tiroefiTie is likely to provide inadequate.
Too many elements and steps, organized only
according to date, are likely to crowd  each
other and make it difficult to follow the overall
communication strategy and to tease out the
principal t^r*tfl^ft  In such cases, th? tJTn«»line!
will be a more valuable planning tool if it is
organized more complexly.

   One way to improve a complex timeline is
color-coding, by means of colored  chalk,
marking pens, underliners, and the Eke. If it
is crucial to keep track of which staff member
is responsible for  which items, for example,
each person's responsibilities can be in a dif-
ferent color.  Or  a  different color can be used
for each audience—efforts to reach local gov-
ernment in blue,  interactions with environ-
mental activists in red, etc. Or a different
color can be assigned to each communication
element and its various steps.  Or you  may
want to .color-code by format— blue for meet-
ings, red for publications, etc.

   Another way to organize the timeline is to
create an "array" of parallel timelines, all
representing the same period but  with each
timeline assigned to a different aspect. The
top line is usually reserved for the calendar
and external events. Meetings and meeting
preparations can be on the second line, publi-
cations on the third, etc. Or— depending on
which organizational principle is most signifi-
cant  for the particular communication
effort— each staff person,  each  audience, or
each element c?" have its own timeline.
   If you use both color-coding and multiple
timelines, of course, you can organize by two
aspects at once.
   At the start of a communication program,
a timeline may seem like more work that it is
worth. But halfway through the program, the
timeline will have proved its worth as a way
of keeping track of what needs to be  done

Evaluating Risk Communication Programs*
A Catalogue of "Quick and Easy" Feedback Methods
Mark Kline, Caron Chess, and Peter M. Sandman
     Agencies thai deal with environmental health issues are paying greater attention to
how they can communicate with the public more effectively. There is also an increasing
body of literature directed to agency practitioners, suggesting how risk communication
principles might be translated meaningfully into reality.
     As these principles are integrated into practice, agencies should also be evaluating
their efforts. Communication efforts, like technical ones, can improve with feedback. The
lack of such feedback may lead the agency to repeat the same communication mistakes and
fail to duplicate successes.
     Unfortunately, it may be difficult for agencies to identify evaluation strategies that
are practical, useful, and affordable.  The term  "evaluation" has multiple meanings,
including making critical judgments about the worth of a program. Therefore, evaluation
activities may seem threatening to agencies already immersed in "crisis" communication
efforts, usually with limited resources. In addition, some forms of evaluation may seem
too elaborate and difficult to implement in this context.
     The goal of this catalogue, which was funded by a contract from the Division of
Science and Research of the New Jersey Department of Environmental Protection, is to
identify and recommend specific evaluation methodologies with the greatest potential for
agency use in small-scale communication efforts where a full-scale evaluation may not be
feasible. These tools arc also likely to have application in risk communication efforts by
industry and advocacy groups.
'Submitted to the Division of Science and Research, New Jersey Dcpartmant of Environ-
mental Protection, September 22,1989, by the Environmental Communication Research
Program, New Jersey Agricultural Experimental Station, Cook College, Rutgers Univer-
sity, 122 Rydcrs Lane, New Brunswick, New Jersey 08903; this paper summarizes the full

                                        Evaluating Risk Communication Programs

Strengths and Limitations or Quick and Easy Evaluation
      In its most general sense, the term "evaluation" refers to a process of interpreting and
judging events, a process that human beings engage in much of the time. Evaluation ranges
alongacontinuum,from infonnaJ.subjcxtivcimprcssionsat one end, toformal.scienufically
conducted and controlled evaluation research at the other (Rossi and Berk, 1988). In the
middle of this continuum are assessment and feedback methods that are more structured
and systematic than subjective impressions, but less rigorous than evaluation research.
Because these intermediate methods require much less time, resources, and expertise than
evaluation research, we cal 1 them "quick and easy" me mods. In our view when most people
think of evaluation they tend to think of approaches that give an overall assessment of a
program's worth.  Such approaches, including "summative evaluation" (Rossi and Berk,
1988) and "impact evaluation", lie at one end of the previously mentioned continuum.
      Many programs go without any evaluation whatsoever because impact evaluation is
seen as the only form of evaluation and these efforts are beyond agency capabilities and
resources. Practitioners may be left with only their own impressions of how they fared in
a communication effort, with no basis beyond intuition and guesswork for correcting
communication errors and repeating communication successes.
      Evaluation experts have generally  accepted this state of affairs because of their
conviction that data from poorly designed evaluation research studies can be misleading.
Rossi (1988) has  noted that a bad evaluation can be worse than not doing one at all
Proponents of rigor have  seen less rigorous research badly abused, leading them to
conclude  that agencies are  better off knowing nothing than obtaining questionable
      We believe  that partial feedback can be belter.than none at all if the strengths and
limitations of this feedback are fully understood. Agencies should not, for example, rely
on feedback from "quick and easy" approaches for impact evaluation. Drawing reliable
causal inferences about the effects of a communication effort requires scientific evaluation
     This catalogue focuses on approaches that we feel are useful when practitioners face
limitations on time, expertise, and other resources. These approaches can be practical for
less resource- intensive communication efforts, where impact evaluation is not appropriate
or possible.
     In lieu of formal impact evaluation, agencies can rely on feedback from quick and
easy approaches to guide the development of their risk communication programs. This is
called "process evaluation," and it examines the ongoing processes and procedures of a risk
communication effort "Formative evaluation" techniques, which assess the strengths and
weaknesses of materials before full implementation of a program, can also be adapted to
suit less resource-intensive communication efforts. Some techniques used in "outcome
evaluation," which explores the reactions of audiences after a phase of a communication
effort, can also be adapted for quick and easy use. Since the use of "quick and easy"
methods generates feedback which is more systematic and disciplined than that found in
typical practice, the use of these methods creates programs that may be ultimately more
amenable to rigorous impact evaluation, should resources become available.

Evaluating Risk Communication Programs
      If "quick and easy" approaches are viewed as a means of obtaining a snapshot—
rather than a full picture—they can provide useful input to agency risk communication
efforts. Practitioners can use quick and easy strategics to gather some information that will
inform their practice in the absence of a full study. In particular, quick and easy strategies
can yield information that can lead to mid-course corrections and bring new ideas into the
process.  This feedback can  be  even more critical to agency efforts than retrospective
analyses. (It may be ultimately more useful for practitioners to know they are about to light
communications fires than to evaluate their firefighting efforts.) Information gathering of
this type is common in the public relations field, where it is viewed as "developmental"
input for generating hypotheses rather than as conclusive  data that are reliable and
general izable.
      Feedback can be viewed as an opportunity to turn bad news into good. Agencies can
use feedback suggesting that a program is off-course to put the program back on track.
Even scathingly negative remarks can be fodder for making a program  more effective.
When viewing feedback as information to succeed rather than as justification, superficial
praise about a meeting or brochure may be less useful than critical remarks that include
suggestions for change. The latter provide the agency an opportunity for improving its
materials and the added benefit of being responsive to the public.
      Agencies should not abandon rigor entirely when gathering information. Quick and
easy methods can be more valuable if agencies attempt to be as rigorous as possible within
the constraints of their resources. For example, keep in mind basic principles of objective
data gathering,  carefully defining target groups, choosing representatives.typical of the
target groups, and asking questions in a consistent and unbiased manner. More rigorous
methods increase the strength of conclusions that can be drawn from feedback. Awareness
of the need for rigor  can also allow agencies to refrain from drawing sweeping and
misleading conclusions from developmental feedback.

 Barriers to the Use of Quick and Easy Evaluation
      We believe these strategies can help communicators develop and maintain an open
channel to those outside the agency.  However, even the best feedback is of little value if
it is not heeded. Audiences may already be skeptical about whether agencies will use their
input and respond to their needs.  If practitioners gather evaluative feedback, they must be
open to using it Furthermore, they should be prepared to assess how the feedback was
used—what role it played in the decision that was ultimately made—and also to demonstrate
any positive effects to the public. Agencies, in short, should be accountable not only for
getting input from the public, but also for using it andshowing that they used it If audiences
sense that their lime and effort have gone to waste, they may be even more disenchanted
with agencies than they would have been if no feedback had been solicited.
      Agencies that operate as closed systems may have little organizational investment
in this kind of feedback. In such  an agency; decisions are made on the basis of an internal
process. Staff are accountable to their supervisors who are in turn accountable to higher-
ups. Communication efforts may be designed to take into account this internal input and
keep things running smoothly. Staff who attempt  to bring in new ideas based on public
input may not be supported. Agencies of this kind may attempt to tend an occasional ear,
pass out an occasional survey, and make an occasional telephone call in an effort to solicit

                                        Evaluating Risk Communication Programs
public input, but the system's incentives make it unlikely that such input .will be used
      Even the best evaluation tool can be subverted by this sort of agency process. For
quick and easy tools to function well in maintaining an open channel, they must be
supported by agency management and policy. Without this support, front-line practitio-
ners may gather information only to have it ultimately ignored, leaving them with an even
more irritated public than in the first place.
      Pan of quick and easy evaluation involves agency management encouraging staff to
be creative in opening the channel with the public—even when what emerges from the
channel is critical of the agency staff members conducting the communication program.
      Agencies, therefore, must be prepared to turn bad news into good. Critical feedback
provides an opportunity to improve a communication effort and a chance to be responsive.
Agencies that are not willing to make mid-course corrections in response to feedback from
the public will have little use for these tools. Agencies may be templed to use quick and
easy strategies to justify what they did rather than to find out what they can do differently.
Aside from being a tedious exercise, using  these tools in this way defeats  their very
purpose—to introduce new ideas and feedback through an open channel.
      Risk communication and quick and easy evaluation arc both value-laden processes.
The valuesandclimatcof an agency can have great impacton whether these tools help open
the door to the public or help keep it shut.  We have attempted to identify tools that support
commonly accepted risk communication principles, hopeful that agencies will use them in
the spirit of an open, ongoing dialogue with the public.
Development of This Catalogue
      This  investigation took the  form  of a scavenger  hunt Through telephone and
personal interviews, literature reviews, networking, and a computer database literature
search, we attempted to identify feedback approaches that we could recommend for agency
practice. We looked for techniques that:

        Arc easy to use
        Can be implemented inexpensively
        Yield results quickly
        Are relatively non-threatening to both the audience and the agency
        Give feedback which translates lo behavioral change
        Reinforce commonly accepted risk communication principles

        Our search was intensive but by no means exhaustive. We talked to a large group
of people, including risk communication practitioners, those with evaluation experience,
consultants, public relations specialists, industry practitioners, and academics. We looked
into their suggestions and reviewed literature  they recommended in addition to literature
we were unearthing. From  this rich mix of sources, we identified the evaluation methods
and instruments reviewed in this catalogue.
     We recognize that we may have missed some instruments, though our networking
efforts did yield confirmation of many of the tools we describe from a variety of different

Evaluating Risk Communication Programs
sources. This catalogue is not intended to be the final word on quick and easy evaluation
strategics. We encourage agencies to continue to look for and develop tools for this kind
of feedback.

How to Use This Catalogue
     Our review of quick and easy evaluation methods is not in the form of a quick and
easy evaluation manual. After agencies have some experience with the instruments we
recommend, development of a step-by-step guide may well be appropriate. We assume
this catalogue will be of most interest to those who have a fair amount of commitment to
and expertise in risk communication. We hope they will use the catalogue as a resource for
assisting policy-makers and technical staff with evaluation.  Nonetheless, we recognize
that most agency staff may not have the time to read a full review of each tool before
deciding which one will be useful to their risk communication efforts.  The following
summaries of twenty-two tools give a brief overview of each. Readers can use these
summaries to decide which tools might prove useful to their communication effort
However, readers will want to review the detailed reports about instruments that interest
them in order to get more in-depth information. (See the full report, as listed on page 45.)
These reports include a) detailed descriptions, including examples of how the instruments
have been used; b) discussion of strengths and limitations; and c) how to order the

                                        Evaluating Risk Communication Programs

I. Planning
      The key to effective risk communication' is effective planning. Just as scientific
research without planning can slow down an assessment due to the need to rethink and
rcsamplc, it is ultimately more wasteful and time consuming to develop a brochure or
presentation without planning.
      It is quite difficult, if not impossible, to evaluate a risk communication effort unless
you have planned a program so that you know what you want to achieve and how you are
going to achieve it Because planning is so critical we have developed a separate document
on planning entitled,  "Improving Dialogue with Communities:  A Risk Communication
Workbook" (Hance et aL. 1988).  This workbook, available in 1989 from NJDEP's
Division of Science and Research or the Rutgers Environmental Communication Research
Program, includes  checklists and worksheets to help those with little  communication
background to identify communication goals, audiences, audience concerns, methods of
reaching people, key content points, and other components of successful planning.
      Our research for this cval uation catalogue did locate some comprehensive planning
systems (Green, 1980; National Cancer Institute, 1989) that could have application in risk
communication efforts, but they arc not "quick and easy"  tools appropriate  for this
catalogue. Other planning tools we located needed significant modification to be useful
in agency settings.

2. Audience Analysis
      One of the keys to successful communication is understanding your audiences in
advance. Agencies need to identify the audiences involved in their communication efforts
and get a sense of what groups already know, what they need and want to know, and what
they expect from the agency. Audience analysts tools provide a means for practitioners to
clarify their perceptions of audiences in organized ways or to solicit feedback from key
audiences before, during and after a communication program. Such feedback can help
practitioners maintain an open channel between the audience and the agency throughout
the communication effort. These strategics arc common in public relations and advertising
practice, where ongoing feedback from an audience is important to respond to changes

2A. Conccptunl/Orgnni/ing Techniques
      These techniques do not involve any data collection from audiences. Rather they are
frameworks to help communicators systematically organize and analyze their impressions
about different types of audiences.

2A-L Policy Profiling Questionnaire
      Purpose:                  To identify  stakeholders  in an issue and organize
                                agency perceptions of them.
      Lead Time:                Low
      Staff Time:                Brief—might include a meeting of involved staff.

Evaluating Risk Communication Programs
      Budget:                  Low
      This tool helps agencies assess their perception of the potential impact that important
actors can have on a decision or course of action. Agency staff identify stakeholders and
numerically rate each of them in three categories:  issue position, power, and salience.
These ratings allow a calculation to determine whether the stakeholder might oppose,
support, or be neutral toward a decision. This tool guides the agency's internal assessment
of relevant stakeholders and involves no formal datacollcction. It is a means for organizing
and comparing perceptions of stakeholders to anticipate reactions to a decision or issue.
However, the ratings arc based solely on the perceptions of agency staff and arc only as
valuable as those perceptions.
  2A-2,  Audience Analysis Matrices
      Lead Time:
      Staff Time:
To identify relevant audiences and organize agency
perceptions of their reactions, involvement, or posi-
tion in a communication effort
        Ma trices are developed which identify relevant audiences and cross-reference the
audience with another important variable— such as issue position, anticipated reactions,
or issue importance.  These, matrices allow a graphic representation of groups in a
communication effort while also encouraging greater awareness of the specific audiences
and their qualities. These matrices arc based only on the perceptions of agency staff-—they
involve no data collection. The instrument may be limited by the degree of knowledge,
intuition, and sensitivity present within the agency.

2B. Preliminary Audience Feedback
        These techniques involve collecting information about an audience in advance
of communicating to help anticipate the audiences's needs and interests.

2B-1. Audience Information Needs Assessment
      Purpose:                   To gather questions from relevant audiences in ad-
                                 vance of public meetings so a response can be orga-
                                 nized and presented.
      Lead Time:                Moderate to high—requires a number of weeks to
                                 mail out inquiry, receive responses, and organize the
                                 information. Lead time may be decreased if telephone
                                 contacts arc used instead of mailed inquiry.
      Staff Time:                Moderate
      Budget:                   Low  to moderate

        Questions from an audience arc gathered in advance of a public meeting so agency
staff can develop a meaningful response.  The agency response may involve both written

                                        Evaluating Risk Communication Programs
and verbal answers to the questions. This approach, which helps agencies meet community
needs, establishes a precedent of listening to the audience and responding to its concerns.
However, it may require loo much lead timcforacrisis situation,and the answers generated
in advance may still meet with disagreement and dissatisfaction from the audience.

25-2. Analysis of News Clippings
      Purpose:                 To identify audiences and their concerns. To develop
                                some historical knowledge of a community to help in
                                planning future phases of a communication effort.
       Lead Time:               Variable, depending on how  far back in time the
                                analysis goes.
      Staff Time:               Variable, depending on the extensiveness of the re-
      Budget:                  Low

        Background informationabout on-going issues is obtained by locating appropriate
newspapers and clipping articles relevant to the issue in question.  The clippings can be
analyzed for a variety of factors, including perceptions of prior agency behavior, public
concerns, principal actors, key events, and community mood. While a useful source of
input and background information, news clippings may reflect media biases, journalistic
sensationalizing, and the inaccuracies of the rush of daily reporting.

2B-3. Public Opinion Polling
      Purpose:                 To assess audience opinion or reaction; to find out
                                what people see as important problems, what issues
                                and events they are aware of. and how they evaluate
                                social and political institutions.
      Lead Time:               Moderate, depending on how formala poll is required.
      Staff Time:          ,     Moderate
      Budget:                  Moderate to high—may involve contracting with a
                                polling firm to obtain useful results.  A low estimate
                                for a very brief formal poll with a relatively small
                                sample is about $2000. Informal telephone surveys
                                may require fewer resources.

        Polling can give agencies a sense of public attitudes and perceptions so the agency
can better  target its communications. Carefully constructed  polls can help prevent
surprises and provide a baseline  for the  later evaluation of the communication effort.
Agencies may hire firms to design and conduct polls on specific issues. These polls benefit
from careful development of the polling questionnaire and random sampling to increase
the reliability of the data. They may also be quite expensive. Informal telephone surveys
involve  briefer questionnaires and smaller samples.   Informal surveys may be more
practical and less expensive, but also less reliable. Polls and surveys tend to consist of

Evaluating Risk Communication Programs
closed-ended questions that limit the richness of the data and can fail to convey the
complexity of public perception.

25-4. Public Opinion PollinglPollstart
      Purpose:                 To organize and analyze polling data on personal
                                computers available within agencies.
      Lead Time:               Moderate to high, depending on extensiveness of the
                                poll, expertise in polling  design available, and
                                knowledge of personal computers.
      Staff Time:               Moderate—depends on previous expertise and skills.
      Budget:                   Moderate.  Pollstart software costs $98.00; Public
                                OpinionPolling. a book that guides use of the software.
                                costs $19.95.

        Pollstart is a piece of computer software which allows agency staff to tabulate and
analyze polling data on a typical office personal computer. The manual for Pollstart
provides step-by-stcp guidance on how to encode (he data within computer files and how
to generate "frequency reports" and "cross-tabulations." Public Opinion Polling provides
useful background on polling and a useful outline of the steps in planning and developing
a poll. The book was written as a companion volume for the software. While this system
provides an excellent review of polling issues, it docs not make the reader a survey design
expert, and less experienced  readers may still  have difficulty designing appropriate
surveys. The software is also not capable of doing more complex data analysis.

25-5. Qualitative Questionnaires                     .:.,.:.
      Purpose:                 To collect information from people whom agencies
                                have involved in a communication effort
      Lead Time:              Low to high, depending on the complexity of the
                                questionnaire and the time needed to develop it. May
                                also require at least two weeks to receive responses to
                                mailed questionnaires.
      Staff Time:               Low to moderate—depends complexity of feedback
                                to be tallied.
      Budget:                   Low to moderate

        Questionnaires are developed, usually in-house, to assess audience positions on
issues or responses to agency process.  Because they may involve a small sample, the
feedback may not be statistically accurate or gencralizablc. These questionnaires can still
provide early input about specific directions an agency  might take, or reasonably rapid
assessment of audience reactions. Questionnaire development, distribution, and tallying
can take considerable effort

3. Message Pretesting
        Agencies can  obtain useful feedback on written materials by having them
reviewed (pretested) in advance of production and distribution. This input can significantly

                                        Evaluating Risk Communication Programs
improve materials so ihey are more easily  understood and communicate the intended
message more effectively.  Message prcicsung may involve surveys and questionnaires,
discussion groups, and/or reviews of the language used in a document. Agencies can assess
whether the document is too complicated for the intended audience, the amount of jargon,
and other aspects of the writing style. We found the work of Uic National Cancer Institute
(1984,1989) to be of great value in exploring and assessing these techniques. v
Brief Approaches
    These techniques give feedback in a short amount of time.
3A-1. Righlwriter
      Lead Time:
      Staff Time:
                           To review documents written on computer word-
                           processing programs for errors in grammar, style,
                           usage, and punctuation.
                           Righlwriicr software currently costs $95.00.
     Righiwritcr reviews documents on computer and creates a "mark-up" copy, includ-
ing feedback on grammar, style, usage, and punctuation in the text, as well as a summary
of the  analysis. This summary  includes a readability  quotient, a strength index, a
descriptive index, a jargon index, and a sentence structure analysis. The summary also
includes a list of words which readers might find difficult to understand. The program is
easy to use and quite rapid. While it can provide a useful feedback mechanism for written
materials, Rightwritcr docs  not "understand" the content of the text and can give no
feedback about tone or appropriateness. In addition, some Rightwritcr feedback may be
confusing, difficult to understand, or irrelevant.

3A-2. SMOG Readability Grading Formula
      Purpose:                 To evaluate the level of reading comprehension a
                                person must have to be able to understand a piece of
                                written material.
      Lead Time:               Low
      StalT Time:                Low
      Budget:                   Low

        This approach involves reviewing a sample of text from a written piece  and
performing some simple mathematical calculations to obtain a SMOG grade, which
represents the reading grade level  a person must have reached in order to understand the
text The higher die grade level, the more sophistication is necessary to understand the
material. Assessment of rcadability.along with a knowledge of the target audience's level
of sophistication, can allow agency staff to produce materials that will be more accessible
to their audiences. Readability quotients are useful as a "first cut" in reviewing drafts of
materials for the public, but  they give no feedback on style, format, tone, or content In

Evaluating Risk Communication Programs
addition, frequent use of long terms that may be necessary in scientific reports may inflate
the SMOG grade.

3A-3. Signaled Stopping Technique
      Purpose:                  To examine how readers process information as they
                                read written materials and through this procedure to
                                get feedback on those materials.
      Lead Time:               Low
      Staff Time:               Low
      Budget:                   Low

        In ihis approach, respondents read through a document and put slash marks where
they stop. They are then provided with a coding scheme to notate why they stopped at each
slash. These reasons for stopping provide feedback to the writer. Respondents may stop
due .to being confused, needing to rc-rcad. having a question, wanting to think about the
idea, or agreeing or disagreeing with the writer. This technique can help writers recognize
confusing or controversial statements within a piece of text and consider revisions, but its
value may be diminished if the reader is unmotivatcd or uninterested.

3B. More folenstve Feedback Methods
       These methods give richer feedback but also take more time to administer.

3B-1. Self-administered Pretest Questionnaires
      Purpose:                  To get feedback on pretest materials.
      Lead Time:               Moderate—allow at least two weeks if questionnaire
                                is mailed.
      Staff Time:               Moderate
      Budget:                   Low to moderate

        Questionnaires about written material ore developed to elicit both quantitative
and qualitative feedback from readers representative  of the intended audience.  The
questionnaire may include questions about format, comprehension, reaction, interest in the
materials, and any other relevant opinions. Questionnaires may include opcn'-cndcd or
closed-ended questions, depending on the items being pretested and type of feedback
desired. The approach may be limited by low response rates to mailed questionnaires and
the amount of follow-up time needed to insure a meaningful response.

3B-2, Central Location Intercept Interviews
      Purpose:                  To gel feedback on pretest materials or to examine an
                                audience's altitudes and opinions.
      Lead Time:       .       Moderate
      Staff Time:               Moderate to high
      Budget:                   Low to moderate

                                        Evaluating Risk Communication Programs
        Interviewers arc stationed at a place frequented by a target audience. They recruit
participants who review materials and then respond to a series of multiple-choice or closed-
ended questions.  The structured interviews provide feedback that can be summarized
quantitatively. Careful planning when using this approach can increase the reliability and
gcncralizability of the data, but central location interviews typically reflect a non- random
sample weighted in favor of those who are able to get to the particular site.  In addition, the
necessity of us ing closed- ended questions may deprive the agency of richer feedback from
a more extended discussion.
3B-3. Theater Testing

      Lead Time:
      Staff Time:
To get feedback on visually presented pretest mate-
Moderate                               \
Moderate to high
        Films, public-service announcements, slide shows, or other audio-visual mate-
rials are observed by a group of respondents in a theater or auditorium. After watching the
film, participants fill out a pretest questionnaire to provide the agency with feedback.
While very useful to improve visually presented messages, this approach may require a
great deal of time and logistical arrangements, in addition to design of the message itself
and the questionnaire.
3B-4. Focus Croups
      Lead Time:
      Staff Time:
To get feedback on and generate ideas about pretest
items. To get a "feel" for the attitudes and beliefs of
a target audience.
Moderate to high
Moderate to high
        A focus group is a discussion session run by a trained moderator. It may include
six to twelve participants, who discuss pretest materials or issues of importance to a
communication effort  Areas covered in a focus group discussion are outlined in the
moderator's guide, which is developed before the session.  Focus group discussions
generally yield qualitative feedback as summarized in a report by the moderator.  These
reports can give an in-dcpth sense of participants' language, their reactions to the materials,
and suggestions for improvement Formal focus groups require careful planning and
moderation and may therefore be too resource-intensive for the average agency. 'Target
audience meetings." involving brief informal discussions with a neutral moderator, a group
typical of the target audience, an agenda planned in advance, and some procedure for note-
taking, can be useful and less expensive.

 Evaluating Risk Communication Programs
  4. Assessment of Communicator Style
         Although agency staff may traditionally focus on "facts" as opposed to relation-.
 ships, conflict in styles can lead to tremendous frustration as well as impasses in a given
 communication. Armed with the facts alone, practitioners may be doomed to skirmish with
 audiences whose very style of perceiving the world and communicating about it differs
 from theirs. Tools in this category can help communicators examine what they bring to the
 communication process. Mostof these tools are sclf-asscssmcntsurvcys that arc completed
 and then scored, providing a profile of the respondent's style, type, and/or motivational
 pattern. This profile provides a model for understanding communication situations, which
 in  turn can help  practitioners gain flexibility within their own style, recognize their
 strengths and limitations, identify the communication styles of people in their audiences,
• and recognize and deal with communication impasses resulting from a clash in styles.
 4'1. Myers-BHggs Type Indicator

       Lead Time:

       Staff Time:
To provide feedback on the communication styles of
agency staff.
Moderate to lengthy, due to time needed to secure
services of consultant
         The Myers-Briggs Type Indicator (MBIT) is a self-report inventory consisting of
 126 questions. It provides feedback on respondents' communication styles in terms of four
 scales: Extraversion-Introvcrsion, Scnsing-lntuition, Thinking-Feeling, and Judging-
 Perceiving. The profiles generated in terms of these four scales include feedback about
 communication strengths and weaknesses.  Communicators can become aware of their
 own strengths and weaknesses while learning to recognize differing communication styles
 in their audiences. The MBT1 model has been used in consultation with risk communi-
 cators and has helped foster flexibility in communication style. However, the psychological
 theory of type underlying the tool may not fully capture the diversity of personality styles,
 and the feedback from this tool is of limited value without a consultation to set it in context
 4-2. Strength Deployment Inventory
       Lead Time:

       Staff Time:
To identify the strengths of agency staff and suggest
ways these strengths can be used to communicate
more productively with others.
Moderate to lengthy, due to time needed to secure
services of contractor.
Moderate.  Each Inventory  form costs $3.45; con-
sultation is additional.
         The Strength Deployment Inventory (SDI) consists of twenty questions, some of
 which refer to situations where things are going well, and some of which refer to situations
 where things are going wrong. The SDI is self-scoring, and respondents identify whether

                                        Evaluating Risk Communication Programs
they arc characterized by any of seven style patterns, each of which implies different
strengths, weaknesses, and motivations which may be reflected in interpersonal com-
munication. The inventory is easy to complete and provides quick feedback about an
individual's style. The SDI model is one way of understanding differences in personal
styles and their impact on communication. A consultation should accompany the tool for
maximum benefit

4-3. Conflict Management Survey
      Purpose:                 To provide feedback about a respondent's approach
                                to conflict
      Lead Time:               Moderate to lengthy, due  to time needed to secure
                                services of consultant
      Staff Time:               Low
      Budget:                  Moderate.  Each survey form costs $5.60 and con-
                                sultation is additional.

      •  The Conflict Management Survey presents scenarios in each of the following
areas: personal views of conflict, interpersonal conflicts, the handling of conflict in task
groups, and conflict in relationships among groups. Respondents note how they would
respond to each conflict scenario, and after a self-scoring exercise, a style preference is
determined, which represents the respondent's preferred mode of managing conflict
Through consultation, respondents become able to understand the implications of their
style preference and develop  the flexibility to use other styles if situations dictate this.
Feedback from this tool may seem threatening if not accompanied by a good consultation.

4-4. Communication Style Survey
      Purpose:                 To provide feedback on the respondent's  style of
                                interpersonal communication.
      Lead Time: .             Moderate to lengthy—surveys need to be mailed to
                                Chicago for scoring, and  a consultation should be
      Staff Time:               Low
      Budget:                   Moderate—standard fee of $140 per person which is

        The Communication S tyle Survey consists of a self-assessment form and "other-
assessment" forms to be filled out by people who know the respondent well. The survey
involves choosing among a set of words the term that most aptly describes the respondent
The data are processed to yield an assessment of communication sty leas some combination
of Analyzing, Facilitating, Advocating, and Controlling. This  Style Profile is accompa-
nied by feedback on the respondent's oral communication competency and adaptability.
Consultation is needed to help respondents understand the strengths and weaknesses of
each communication style and develop flexibility.

Evaluating Risk Communication Programs
5. Outcome Assessment
      Agencies typically view evaluation as a means or finding out whether what they did
worked or not. As suggested earlier, carefully designed scientific evaluation research is
required to draw these kinds of conclusions.  When agencies have little time and few
resources, however, they may still need to find out how audiences have reacted to phases
of the communication effort and to the effort as a whole. The outcome tools we recommend
providestrategicsforgcuingfccdbackonaudicnccrcaciion and communicator performance.

5A.  Audience Reaction
        Audiences are asked what their reaction is to a presentation.
SA'l. Meeting Reaction Form
      Purpose:                  To get feedback about participants'  reactions to a
                                public meeting.
      Lead Time:               Low to  moderate, depending on whether the form
                                developed by the Environmental Communication
                                Research Program needs modification for specific
                                agency use.
      Stall Time:               Moderate—includcsprcparauonof form,distribution,
                                and data analysis.
      Budget:                  Low

      The Environmental Communication Research Program has developed a form for
distribution  at public meetings which examines whether information was understood.
whether presenters were perceived as honest, whether people felt their concerns and issues
were understood, whether people felt their input would be used in decision-making, etc.
Other relevant issues can also be addressed. The particular form described in this catalogue
was designed to get feedback from various constituencies involved in a public participation
program run by the Bureau of Water Quality Standards and Analysis (B WQSA) of the New
Jersey Department of  Environmental  Protection. While it provides a quick, easy, and
inexpensive way to get feedback about a public meeting, the form is not standardized or
scientifically validated and some feedback could be difficult to interpret

SA-2. Verbal Meeting Feedback
      Purpose:                  To get direct feedback from participants at a meeting.
      Lead Time:               Low
      Staff Time:               Low
      Budget:                  Low

        Time fora structured feedback discussion is planned in a meeting agenda. The
meeting chairperson actively solicits and may even record this feedback on a chart for
everyone to sec. Participants should feel free to com mcnt on any aspect of the meeting, and
conflicting statements are allowed. The goal is to generate  as many idea as possible rather
than  going into detail on any one idea. This approach is highly dependent on the skill of
the chairperson in creating a comfortable environment for feedback and inviting partici-

                                        Evaluating Risk Communication Programs
pation. Less verbal members may not be heard, and it is difficult to know whether this kind
of feedback is in any way representative of the views of the group as a whole.

5B.  Performance of Presentation
      These techniques provide feedback more specific to how the communicator per-
forms than how the audience reacts.

5B-L Speech Evaluation Checklist
      Purpose:                 To get feedback on how a speech or presentation
      Lead Time:               Low to moderate-depending on design of form.
      Staff Time:               Low
      Budget:                   Low

      The Speech Evaluation Checklist is a simple form to get feedback on a speech or
presentation.  It may include statements about the physical setting of the speech, the
speaker's appearance-, rapport, comprchensibility. and other important areas. The forms
can be completed by one or a number of evaluators who observe the speech. Alternatively,
a speech can be audio- or video-taped for use for scoring by the presenter. The form is not
intended as a "report card," but as a chance to get some input on a speech that will improve
future presentations. This approach can provide immediate, relevant written feedback, but
the perceptions of other agency staff may differ markedly from the perceptions of the

50-2. Observation and Debriefing
      Purpose:                 To get feedback on speeches and presentations.
      Lead Time:               Low to moderate—time needed to develop an ob-
                                server checklist
      Staff Time:               Low
      Budget:                   Low

      One or a number of observers attend a presentation and take organized notes, using
their perceptions of the event and some kind of observer checklist based on the goals of the
presentation. An informal verbal debriefing session may be held after the presentation to
review important strengths and weaknesses with regard to both the speaker's performance
and the audience's reactions. The presenter can also use an audiotaped  or videotaped
version for self-assessment. While this is a quick and easy way to provide feedback on a
speech, it should not substitute for finding out the audience's actual reactions, and it can
be uncomfortable for the observers or the presenter depending  on their roles within the


Evaluating Risk Communication Programs
 Briggs, K.C. and Myers, I.B. 1976. Mvcrs-BrippsTvpe Indicator. Form G. Palo Alto,
 CA: Consulting Psychologists Press, Inc.

 Green, L.W., Krcutcr, M.W., Deeds, S.G., and Partridge. K.B. 1980. Hcalih Education
 Planning;  A Diagnostic Approach. Palo Alto, CA: Mayfield Publishing Company.

 Hance, BJ., Chess, C., and Sandman, P.M. 1988. Improving Dialogue with Commu-
 nities:  A Risk Communication Manual for Government.  Trenton, NJ:  New Jersey
 Department of Environmental Protection, Division of Science and Research.

 National Cancer Institute.  1984.  Protesting in Health Communications:  Methods.
 Examples, nnd Resources Tor Improving Hcnlih Messages and Mnicrials. Washington,
 DC: National Institutes of Health, N1H Publication #84-1493.

 National Cancer Institute.  1989. Making Henlih Communication Programs Work:  A
 Planning Guide. Bcthcsda. MD:Nalional Institutes of Hcalih. NIH Publication #89-

 Rossi, P.H. and Berk, R.A.  1988. A Guide to Evaluation Research Theory and Practice.
 Discussion Draft prepared for the Workshop.