Student Manual

                 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

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Dealing with the Media/Handling Tough Questions	IV

Explaining Technical Issues	V

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
not 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 objectives
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 the 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

      The 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 public.  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. 1 IS. 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

Risk Assessment, Risk Management, and
Risk Communication
Prepared for:
EPA Environmental Protection Agency

The likelihood of injury, disease, or death

The likelihood of injury, disease, or death
resulting from human exposure to a
potential environmental hazard

   Evidence often comes from animal
   - Extrapolated to humans

   Process of risk assessment is a complex
   one - with a lot of uncertainty

   Questions about the process and results
   make it difficult to communicate these

Four steps in risk assessment as described
by the National Academy of Sciences

Conduct experiments or use epidemiological
data to determine if the chemical causes
certain effects

  An analysis of the "strength of
  evidence" that the chemical would
  lead to the effect
  Review and analyze toxicity data
  Weigh the evidence that a substance
  causes various toxic effects
  Evaluate whether toxic effects in one
  setting will occur in other settings

Assessor chooses a classification based
on estimation of strength on human and
animal evidence

No data
No evidence


Limited Inadequate

No Data

No Evidence


Group A
Human Carcinogen

Group B
Probable Human Carcinogen

Group C
Possible Human Carcinogen

Group D
Not Classifiable

Group E
Negative Evidence

  Hazard            Risk
Identification     Characterization


s \
X /}
y>" \X X
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Using data from hazard identification, assessor
dose range - where you often have no data
^^^ Range
Range of

must determine what happens in low

   Response .33-
(Probability of
     Cancer) .10-
                   Linearized Multistage Model (LMS)
                      (upper confidence limit)

EPA uses the LMS Model - the most protective

  of Cancer) .0228 _

The unit cancer risk represents the probability of developing cancer
from exposure to one unit of the dose.

                      Liver Damage
    NOAEL = No observed adverse effect level

               RfD   NOAEL
RfD = Reference dose             (mg/kg/day)
NOAEL = No observed adverse effect level


 Extent and frequency of human exposure
 Number of people exposed
 Degree of absorption by various routes of
 In estimating likely exposure to a
 population, assessors will use assumptions
 for both average or typical individuals and
 high-risk groups (children, elderly)
 Final result of exposure assessment is an
 estimate of the dose that various population
 groups will be receiving

  Hazard      X^    Risk
Identification   (Characterization


   Quantification of risk posed
   - For cancers, it is the product or the
     exposure assessment X the estimated
     unit cancer risk

   The characterization also contains
   qualitative information describing
   uncertainties, questions, and strengths
   in the assessment


In characterizing the risk, Assessor must:

   Integrate and summarize the hazard
   identification, dose-response
   assessment, and exposure assessments

   Develop public health risk estimates

   Present assumptions, uncertainties,
   scientific judgements


• Hazard           Use of animal data, epidemiological
  Identification      studies
  Dose-Response    Extrapolating from high dose
  Evaluation        to low dose
                   Extrapolating from animals to

  Human Exposure   Modeling versus ambient
  Evaluation        monitoring versus biological

  Risk             Uncertainties in data

   Actions that reduce environment risk
   Data from risk assessment
   Information on control options
   - Economics
   - Available technologies
   - Legal constraints
   Input from affected parties


       A Broader Definition of Risk

  aicif   -     Technical           Non-Technical
  rilOiA   —        ri« i          +       n II-
                   Risk                 Public

               Assessment           Concerns
              Peter Sandman

  RISK   =      Hazard        +    Outrage
Source: Adapted from Peter Sandman, Rutgers University.


  Controlled by Individual
  Morally Irrelevant
  Visible Benefits
  Trusted Source

Man Made
Controlled by Others
Morally Relevant
No Visible Benefits
 Untrusted Source
Source: Paul Slovic, Baruch Fishhoff, and Sarah Lichtenstein.

        Does Outrage Affect Policy?
Public Fears
and Outrage
                     Technical Risk


   Two-way (or more) transfer of information
   and of view points

   The opportunity for the public to use
   information to participate in the
   decision-making process

   The opportunity for decision-makers to learn
   from the public


   Risk communication addresses, but
   does not redress, inequities in risk

   Involving people means empowering
   them; treating them fairly

   Agency must actively seek input from
   those not necessarily involved in
   environmental risk issues
   - Hold smaller, more informal meetings
   - Ensure that message content meets
     audience needs

Planning as TQM process
   Focus on customer
   Identify key points in process
   - Who needs to be involved?
   - What are potential problem areas?
   Involve all team members in plan

Six Basic Steps
   Clarify risk communication goals and
   Define success
   Determjne information needs for
   Collect the information
   Analyze the data
   Draw conclusions and modify approach
   if necessary to help reach objectives


Three types of evaluation

   Formative - planning and pretesting
   your concepts to see if they will reach
   the right people and will be

   Process - Tracking the process used to
   implement your strategy

   Outcome - Tracking the impacts or your
   communication strategy. Be willing to
   change your plan based on these results

 1. Accept and involve the public as a
   legitimate partner
 2. Plan carefully and evaluate your efforts
 3. Listen to the public's specific concerns
 4. Be honest, frank, and open
 5. Coordinate and collaborate with other
   credible sources
 6. Meet the needs of the media
 7. Speak clearly and with compassion



      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 part 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

      f ?    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 pan 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 by 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 Earlv. developed at Rutgers.
              Discussion Questions  -  Explaining Technical
   1.  How do you justify making decisions about which you have doubts?
   2.   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?
HISK 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
efforts.                              '•'-•.

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 Early. 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
panics 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

       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

   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
      Branch, suspect that something might be stirring in the wind concerning Alar, a
      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 the 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 lor Risk Communication- 4

Evaluation options based on available
   Type of
           Possible Options Based on Available Reasons

 Minimal Resources        Modest Resources        Substantial Resources
Readability test
Central location
intercept interview
Focus groups, individual
in-depth interviews
Program checklist
Management audit
Activity assessments
                Print media review
Progress in attaining
                    Public surveys
Assessment of target
audience for
knowledge gain
                      Studies of public
                      behavior/health risk change
                                                         Planning for Risk Communication- 5

    f|      Additional Readings in Resource Section -
    y      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 ASARCO
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 effons?
             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 ASARCQ/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 converters.
Gases collected from the furnaces and the hoods enter the pollution control system,
and arsenic, SO2, and particulates 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 SO2,
 paniculate, 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 S02. 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 converters, 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 converters 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.
    •  t
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 Robert 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 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

   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 convener 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 convener 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 pan, 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 Tacoma 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/Iiter, 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.
*""L^    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 ASARCO 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.
      J       Exposure Evaluation
      M fi
       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.
                                 TABLE  1
                        OF THE ASARCO SMELTER
    Current   Emissions

       (million  grams)

 EPA's Estimate:
 Stack:                     148
   converters               120
   others                   	1£
 Total:                     282
 ASARCO's Estimate:
 Stack:                      37
   converters                   8
   others                   	8
 Total:                      53
 PSAPCA's Estimate:
 Stack:                      64
  converters                   5
  others                     24
 Total:                      93
     Emissions  After
      (million  grams)

EPA's Estimate:
ASARCQ'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 iig/m^) 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 \LjJrt?.

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/yearwithabest
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 ASARCO 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 IS
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 list of key
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 pan 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


|AH-fRLJ37S-JI  - —

National EmlMlen Standards for
Hazardous Air PoHutantK Propoeed
Standards for Inevojanlc Arsenic

AOIMcr Environmental Protection
ACTOK Propoied rule snd
announcement of public hearing.
             June 5. 1080. EPA lilted
inorganic arsenic as a hazardous air
pollutant under Section 112 of the Clean
Air Act. Pursuant to Section 112. EPA is
proposing strrdards for the following
categories of ..urcea of emissions of
Inorganic aroenic high-arsenic primary
copper smelters, low-enemc primary
copper smelters, and glass
manufacturing plants. EPA identified
other categories of sources emitting
inorganic arsenic and. after careful
study, determined that the proposal of
standards for these categories of sources
is not warranted at this time. These
categories of sources are primary lead
smelters, secondary lead smelters.
primary sine smelters, xinc o^tde plants.
cotton gins, snd arsenic chemical
manufacturing plants.
            1 below.

Public Hearings aod Related Information
  Commentt. Comments must be
received on or before Seotember 30.
  Public Hearing. Two public hearings
will be held. The first hearing will be
held in Washington. D.C. on August 23.
24. and 25.1083. beginning at OfiO 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
harsadous 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-arsenic coppers smelters. (2)
low-arsmic copper smelters. (3) gless
manufacturing plants, and (4) others.
Persons planning to attend the first
heanng msy call mrs. Naomi Durkee
(910) 541-8578 after August 18.1083. to
                       obtain an estimated time and date at
                       which each subject will be addressed.
                         The second hearing will be held in
                       Tacoma. Washington, on August 30.
                       1083. This hearing will be for the
                       purpose of receiving comments on the
                       proposed standards for high-arsenic
                       copper smelters. This hea- ng will be
                       held fromm 12:00 noon to liTO p.m. and
                       may be continued on August 31.1083. if
                       necessary to sllow all persons wishing
                       to speak an opportunity to do so.
                         Requett to Speak el Hearing- Persons
                       wishing to present oral testimony at the
                       Tint heanng must notify Mrs. Naomi
                       Durkee by August 15.1083. at telephone
                       number (010) 541-8578 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.
                       1083. at telephone number (208) 442-1080
                       or mailing address: Air Programs
                       Branch. U.S. Environmental Protection
                       Agency. Region X. 12008th Avenue.
                       Seattle. Washington. 08101.

                         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 20480.
                       Specify the following Docket Numbers:
                       OAQPS-7B-4  Uslinaofarsamcasa
                         htfS«iUuus pollutant
                       A-40-M High-arsenic and low-arsenic
                         copper smelters
                       A^9-6 Class manufacturing plants
                       A-«3-e Secondary lead
                       A-43-10 Cotton gins
                       A-tt-ll  Zinc oiide plants
                       A-63-U Primary sine, primary I  «d. arsenic
                         chemical manufacturing
                         Public Hearing. The public leering to
                       be held on August 23.24 and 25.1083.
                       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 30.1083. will 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 US. Environmental
                       Protection Agency library (MD-35).
                       Research Triangle Park. North Caroline
                       27711. telephone 91W41-2777. Please
                         EPA 4SO/»-83-OOOa Inorganic Arsenic
                       Emissions From High-Arsenic Primary
Copper Smellers—Background
Information for Propoied Standards
  EPA 450/3-43-010a Inorganic Arse
Emissions From Low-Arsenic Pnmar
Copper Smellers—Background
Information for Proposed Standards
  EPA 450/3-83-Olla Inorganic Arse
Emissions From Class Manufactunn.
Plants—Background Information for
Proposed Standards.
  EPA 450/5-82-005 Preliminary Stu
of Sources of Inorganic Arsenic.
  Dockett. 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'*
Central Docket Section. West Tower
Lobby. Gallery 1. Waterside Mall. 40
Street. SW.. Washington. D.C. 20460.
reasonable fee may be charged for
copying. The following dockets are
OAQPS-79-8  U«ung of •raentc *i •
  hatardous pollutant
A-40-40  High-arsenic and low-araemc
  copper inulten
A43-8  Glass manufacturing plann
A-e>«  Secondary leed
A-43-10  Cotton fins
A-63-11  Zinc oiide pUnu
A-e»-21  Primary tine, primary lead, art
  chemical manufacturing

  The docket A-80-40. which contai
the supporting information for the
proposed standards for high-arsenic
low-arsenic copper smellers, will als
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 (206) 442-.
or at mailing address: Air Programs
Branch. U.S. Environmental Protecti
Agency. Region X. 1200 8th Avenue.
Seattle. Washington. 08101.

              Federal Register /  Vol. 48. No.  140 / Wednesday. July 20. 1983 / Proposed Rules
praptrly optnttd tad maiataiatd.
Continuous monitorial of airflow would
bt required to oasora tat secondary
hood system Is boiaf praptrly operated
•ad maintained.
  Thi propoMd standards would
regulate laorgaaic arsenic emissions
from primary eopptr smtlters that
proctu fatd matarial with aa anaual
average laof|aaie arseaic eoataat of 9.7
weight parooat or more. The propoaad
•taadarda would require the uaa of baat
avaUabla technology (BAT) to unit
Moondary Inorganic araaaic emissions
from eopptr converting operations.
Secondary laorfaaic arsenic emissions
are tmiaiioaa that ncapt capture from
the primary tmiailoa coatrol system.
The BAT for the capture of aeeoadary
Inorgaaic arsenic emissions from
converttr charging, blowing, skimming.
holding, aad pouriag optratioat la a
secondary hoed •yattm consisting of •
fixed enclosure with a horixootal air
eui .«..L For collection of secondary
inorganic arsenic emissions. BAT to a
baghouae or equivalent coatrol device.
The proposed itaadards are expraised
in terms of equipment specifications for
the capture ayitem aad a •'••t""in
allowable paniculate tmintoa limit for
the collection device. Paniculate
eraissioas from the eoUtctfoa device
would aot bt permitted to exceed 114
milligrams of partlculates par dry
standard cubic meter ef exhaust gas
(mg/dscm). This limit reflects BAT for
collection of secondary inorganic
arsenic emissions.
  To determine tat applicability of the
proposed standards to a primary eopptr
smelter, the iaorgaaie arseaic coattat of
the feed materials would bo measured
using the proposed Reference Method
10BA. To determine  compliance with the
proposed paniculate tmissioa limit.
Reference Methods 1.2.3. aad S la
Appendix A of 40 CFR Part 60 would bo
used. Continuous opacity monitoring of
gsses exhausted from a paniculate
control device would be required to
ensure the control device is being
  The proposed standards would affect
primary eopptr smelters that process
feed malarial having aa aaaaal average
inorgaaic antaie eoataat ef O? wtight
percent or mort. This category la
defined aa high-erseaio-throughput
smelters. Tat oaly existing primary
copper smelter la the higb-araaate'
throughput smtlttr eattgory Is owaed
aad operated by ASAROQ, laeatperattd
( ASARCO) aad located In Taeema.
Washiagtoa. Tat aaaaal avtragt
Iaorgaaie antaie eoataat of tat feed
material Is act txptetad to be lacreaaad
to OJ paresat or above at aay ether
existing amtlttr, and ao atw smelters
art protected te be built. Fer this raasoa
only the ASARCO smelter located la
Tacoma. Washiagtoa (hereafter referred
to ae the ASARCO-Tacoma amtlttr).
baa beta analysed for the purpose of
calculattag the healthi environmental
tcoaomife aad aatrgy Impacts of tho   '
proposed stead lids.
  As will bt dlacaaatd la tat atxt
section. to facilitate regulatory eaalyais
EPA has aeparattd the primary eopptr
amaltiag mdustry late two source
categories based ea the aaaoal average
laorgaaic arstaie eeateat ef the smelter
feed material. Primary copper emeltora
which pi
                d material with aa
    lei average laorgaaic araealc
conteat less taaa O7 weight percent ere
addressed in Part m of this proamblt.
  The proposed staadards weald reduce
total Iaorgaaie arseaic emissions from
the ASARCO-Tacoma smelter from the
current Itvtl ef 282 megagrams (Mg) (311
tons) per year te a level ef 178 Mg (188
teas) par ytar. Aa a result ef this
reduetioB in laorgaaic arseale emissions.
it is estimated that the aumbtr ef
inddtncts of lung cancer due to
inorganic arsenic exposure for the
approximately 370400 people living
within about 20 kilometers (124 miles)
of the ASARCO-Taeoma smelter would
bo reduced from a range ef LI to 174
incidences per ytar to a range of 0.2 to
3.4 incidences per year. The proposed
standards would reduce the estimated
•"-•«•""• lifetime risk from exposure to
airborne Inorgaaic arseale from a range
of 24 to 37 la 100 to a range of 048 to 92
in 100. The maximum lifetime risk
represents the probability of a person
contracting cancer who has beta
exposed continuously during a 70-year
period te the maximum aaaaal laorgaaic
arseaic eoacaattatioa due te inorganic
arsenic tnrttrlimt from  the ASARCO-
Taeoma smelter. (These estimated
health Impecta were calcalatad based
oa a anmber ef assumptions aad contain
considerable uacertaiBty as itisnisssil In
Part I of this preamble and la Appendix
E ef the beckgrouad Information
  Applicattea of the centrals reo>
by the proposed standards would
lacreese the amount ef solid weste (i.e.
eollacied paniculate matter containing
iaorgaaie arseale) entering the
ASARCO-Taooma amaltar waste
disposal system by approximately 11
gigagrams (Gg) (12400 teas) per year.
Cumatly. the ASARCO-Taeoma amtlter
gtaaratts approximately 182 Cg (200400
teas) per year of solid waste (including
flee) The additional amount of solid
weste geaerated can be haadled by the
existing waste handling system at the
smelter. Because the central systems
expected te be used to achieve the
proposed ataadards are dry systems.
there would bt ao water pollution
  Energy Impacts under the proposed
staadards would bt Increased electrical
power consumption. The anaual energy
requirement for the  ASARCO-Tacoma
smelter Is approximately 24X10*
kllowstt-hours per year (kWh/y).
Additional energy requirements at the
ASARCO-Taeoma smelter due to the
proposed standards are estimated to be
approximately UxlO* kWh/y.
representing en Increase In the annum

Federal  Register  /  Vol. 48.  No. 140  /  Wednesday. |uiy 20.  1983 / Proposed Rules
smeller energy consumption of about O.S
  For the ASARCO-Tacoma smeller.
capital and annuaMzcd costs required to
meet the proposed standards would be
approximately $3.5 million and Si.5
million, respectively. The primary
economic impacts associated with the
proposed standards arc protected
decreases in profitability for the
ASARCO-Tacoma smelter, li is
anticipated that the proposed standards
will not adversely affect the economic
viability of the smeller 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 Catenary
  Copper smelting 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
smellers are 1.012 megagrams (Mg)
(1.116 tons) 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 smelter located in
Anaconda. Montana (this smelter was
permanently closed in 1981). The
National Cancer Institute has released a
study showing excess mortality from
respiratory  cancer in counties where
primary copper smelters are located.! IV)
  C.PA initiated a study  in 1977 of the
populations exposed to vdr.ous 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 BO kilometers of selected smelters
was 10 times greater than the annual
average for all of the sues (in excess of
250) in the nationwide network. At a site
within 18 kilometers of the ASARCO-
Tacoma smeller, the annual average
was more than 25 limes the national
  Based on information provided by the
copper smelting industry. EPA has
determined that the ASARCO-Tacoma
smelter processes feed containing a
higher concentration of inorganic
arsenic than any other primary copper
smelter in the United Slates. The
ASARCO-Tacoma smelter is a custom
smelter. ASARCO purchases ore
concentrates from other mining and
milling producers to process at its
                        Tacoma smelter. Typically, feed
                        material containing on the average 4.0
                        weight percent inorganic arsenic is
                        processed at the ASARCOTdcoma
                        smelter at the rale of 940 kilograms of
                        inorganic arsenic per hour (kg/h|. The
                        level of inorganic arsenic conrnntnuion
                        in the feed materials processed at the
                        ASARCO-Tacoma smeller is an order of
                        magnitude greater than the level
                        processed at the other 14 primary copper
                        smellers. 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 at a domestic smelter
                        is approximately 170 kg/h. In fact, the
                        inorganic arsenic process rale 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 smellers.
                        Consequently, the benefits associated
                        with the application of specific control
                        technologies to the ASARCO-Tanma
                        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 lo
                        separate smelters into two source
                        categories based on the annual average
                        inorganic arsenic concentration in the
                          The source category for high-arsenic-
                        throughput smelters is primary copper
                        smellers 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 existing
                        smelters other than the ASARCO-
                        Tacoma smeller. 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 H.
                        Part III of this preamble.
                          EPA has. aa a matter of prudent health
                        policy, taken the position that human
                        carcinogens must be treated aa posing
                        some risk of cancer HI 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
Administrdlor has determined thnt
inorganic arsenic emissions from nign-
iirscmc-ihroughpul smelters are
significant and should be rpguidte'i
  In making the decision to roguidie
hixh-.irsanie-throughpui smelters, inn
Administrator considered whether ot.i-
regulations affecting high-ursenic-
throughput smelters were adequate tu
control dimosphenc inorganic arsenic
emissions. The Administrator has
concluded that existing regulations tr?
not adequate to protect the public heai
and welfare from sources of inorganic
drsenic emissions at high-arsenic-
throughput smellers with an ample
margin of safety. Based on an analysis
of the costs and impacts of more
stringent alternatives, it is the
Administrator's judgment that a
substantial reduction in inorganic
arsenic emissions to the atmosphere
from the current level is achievable dm
npprupriate. Therefore. EPA has decici
to proceed with the development of
standards lo control inorganic arsenic
emissions from high-arsemc-throughpu
smelters under Section 112 of the Clear
Air Act.
  EPA expects that only the ASARCO-
Tacoma smeller would be in the high-
arsenic-throughput smelter source
category. Should any other existing
smelter process feed materials having
an annual average inorganic arsenic
feed content above 0.7 weight percent.
the smelter would become subject to th
proposed standards. In addition, the
proposed standards would also apply t
any new smelter processing feed
materials with an annual average
inorganic arsenic concentration of 0 r
weight percent or more.
  Other than the ASARCO-Tucomu
smelter, no existing smelter is expectcL
to process feed materials having an
annual average inorganic arsenic feed
content above 0.7 weight percent wiihi
the next 5 years. Also, it Is projected
that no new domestic primary copper
smellers will be built within the next 5
years. This projection is based on EPA
conclusion that annual Industry growir
will be accommodated by existing
smelters, which are presently not
operating or are operating below
Description of Smelting Process and
Emission Points

  A primary copper smeller is a facility
that produces copper from copper
sulfide ore concentrates using
pyrometallurgical techniques. These
techniques are based on copper's itror.
affinity for sulfur and Its weak affinity
for oxygen as compared to that of iron
and other hate metals In the ore. The

              Federal  Regular /  Voi. 48.  No. 140 / Wednesday. |uly  20. 1963  /  Proposed  Rule*	3312£
purpose of smelling is to separate the
copper from the iron, sulfur, and other
impurities present in the ore
  Primary copper smalUAg 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 can (called "larry can"). This
operation is called "calcine
  The larry can transfer the calcine to a
smelling furnace. At moat smelten. raw
copper sulfide ore concentrate is
charged directly to the smelting furnace.
In the smelting furnace, the calcine or
raw. unroasted ore concentrate IB
heated to form a molten bath containing
separate layen 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 walla
(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 launden. which
empty the matte into ladles. This
operation is called "matte tapping."
  The ladle ia transported by an
overhead crane to a copper converter.
The molten matte ia poured from the
ladle into a large opening on the top of
the converter vessel. Air is blown into
 ... converter to first oxidite the iron
sulfide 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 to the anode casting
area (for casting of the copper into
copper anodea).
  Roaster and smelting furnace offgase*
dre produced by the combuation of fuel
and the reaction of matenala In the high-
temperature environments. Converter
offgases result from blowing air through
the mane and the reaction of matenala
in the molten matte. Inorganic arsenic in
the ore concentrates is volatized during
roasting, smelting, and converting, and
is exhausted from the process
equipment in the*6ffgases. Offgases
discharged from roasten. smelling
furnaces, and converters, in the absence
of any controls, would have the highest
inorganic anenic emissions of any of
the copper smelting sources at the
ASARCO-Tacoma smeller. An inorganic
arsenic material balance was provided
by ASARCO and reviewed by EPA lo
inventory the inorganic anenic Inputs
versus outputs from each process al the
ASARCO-Tacoma smelter. The material
balance shows that the inorganic
arsenic emission rales in the absence of
any controls would be 25S kg/h for the
roasten. 608 kg/h for the smelting
furnace, and 207 kg/h for the converters.
  During converting, moat of the
remaining amount of Inorganic anenic
and other impurities originally in the
copper ore are removed from the copper
matte to produce blister copper (98 to 98
percent pure copper). Bliater copper
from the converten may be further
refined in anode fumacea prior to
casting of copper anodea (solid slabs of
blister copper). Because of the small
quantity of inorganic arsenic remaining
in the blister copper charged to the
anode furnace, inorganic anenic
emisaions from anode fumacea are very
low when compared to the inorganic
anenic emissions from roasters.
smelting fumacea. or converters. The
material balance for teh ASARCO-
Tacoma smelter shows that inorganic
anenic emissions from anode furnaces
in the absence of any conlrola would be
0.4 kg/h.
  The ASARCO-Tacoma amelter ia the
only primary copper amelter that
recoven arsenic from collected waste
materials. Oust collected in the flues and
control devices at the smelter is
processed to produce arsenic trioxide
for sale to anenic chemical
manufacturing companies. In addition.
metallic anenic ia produced al the
smelter site. The material balance
shows that inorganic anenic emissions
from the anenic trioxide and metallic
anenic manufacturing processes in the
absence of any controls would be 376
   Secondary inorganic anenie
emissions from converten are those
emissions that escape capture from  the
primary emission control system. When
the converter is rolled out fur chargin-
matte into the converter mouth.
skimming alag formed in the converter.
or pouring bliater copper into a ladle, the
primary hood is 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 anenic because these
operations occur outside the range of the
converter'a primary offgas exhaust
hood. Additional secondary inorganic
anenic emissions also escape capture
by (he primary offgas exhaust hood
during blowing and holding operations.
For the ASARCO-Tacoma smelt*   e
material balance shows thai tht
secondary inorganic anenic emiu..-.t«
rate from converter operaliona in the
absence of any controls would be 14 kg/
  Secondary inorganic arsenic
emissions also escape lo the atmosphen
during calcine discharging at the roaster
and during malle lapping and slsg
tapping al the smelting furnace. An
estimate based on the material balance
for the ASARCO-Tacoma smeller show*
that inorganic anenic emissions from
matte tapping in the absence of any
controls would be 4 kg/h. Inorganic
anenic emissions from calcine
discharging and slag tapping are
estimated to be lesa than 1 kg/h.
Secondary inorganic anenic emissions
from anode furnace operationa 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 dual chambers. At
the ASARCO-Tacoma amelter these
activities are conducted at many
locations throughout the plant Although
the amount of inorganic arsenic
emissions al each location is ve*    ill
the cumulative total of emission:
many locations can be a significatii
quantity. The material balance for the
ASARCO-Tacoma smelter shows that
secondary inorganic arsenic emissions
from miscellaneous sources would be
about 6 kg/h in the abaense of any
Policy for Determining Control Levels
  For this source category, which
consists of only the ASARCO-Tacoma
smeller, a three-step approach has beet
followed lo 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 considen economic
 feasibility: «nd. for this smelter. BAT
 does not exceed the most  advanced
 level of control that the smelter could
 afford without closing.
   For those emission points whi
 is in place. EPA determines whet.
 NESHAP standard is needed to assure

               Federal Reyster  /  Vol. 48.  No. 140  /  Wednesday. July 20. 1983 / Proposed Rules
that BAT will remain in plan and will
be proptriy eptrtled and maintained. A
primary consideration It (he existence of
other Federally enforceable standards. If
BAT is not in place on spcciCc 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 denned
based on demonstrated control
technology. The environmental.
economic and energy impacts of the
alternatives are determined. Based on
an 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 smelter is estimated.
This estimated risk which remains after
application of BAT is evaluated
considering costs, economic impacts.
nsk reduction, and other impacts that
would result if a more stringent
alternative were selected. If the residual
nsk is (udged not to be unreasonable
considering the other impacts or beyond
BAT controls, more stringent contrail
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 Control*
  Inorganic arsenic emission sources at
the ASARCO-Tacoma smelter are
currently controlled using a variety of
capture and collection techniques.
Capture techniques are uaed to gather
and confine secondary inorganic arsenic
emissions and to transport them  to a
collection device. Collection techniques
are used to remove inorganic arsenic
from process ofTgases and captured
gases prior to venting the gaaea to the
atmosphere.  Each inorganic arsenic
emission source at the ASARCO-
Tacoma smelter waa examined by EPA
10 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 smelter 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
offgaaea. the inorganic arsenic vapor
condenses to form inorganic arsenic
paniculate*, 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 the
inorganic arsenic saturation
concentration at gas temperatures less
than 121* C (250T). 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
paniculate matter.
  Roaster process offgases at the
ASARCO-Tacoma smelter are cooled to
a temperature less than 121* C and the
inorganic arsenic particulates are
collected in a btghouse. 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 offgaaes 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 offgaaea are first
cleaned by passing the gaaea through a
water spray chamber, an electrostatic
precipitator. scrubbers, and mist
precipitators. This gaa cleaning process
removes over 99 percent of the
contaminants, including inorganic
arsenic, from the offgaaes pnor to
entering the SO» or acid plants. In the
event that the volume of converter
process offgases exceeds the capacity of
the SOt and acid planta or when the
plants are not operating, the excess
converter offgaaea are diverted to an
electrostatic precipilator. This
electrostatic precipitator alao serves aa
the full-time control device for the anode
furnace process offgases. Cooling 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
process offgases are in place at the
ASARCO-Tacoma amelter in order to
comply with existing total paniculate
emission regulations of the Puget Sound
Air Pollution Control Agency (PSAPCA).
These regulations are expressed in
leans of very stringent process weight
paniculate 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 paniculate 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
ihe high inorganic arsenic vapor
concentrations in the process offgases <*i
a high-arsenic-throughput smeller.
cooling of the offgases to below 121* C
results in condensation of the vapor to
form particulates. Thus, collection of the
inorganic arsenic paniculates in
properly designed and operated
paniculate 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 offgaa 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 Federally enforceable
regulations require the controls to
remain in place and to be properly
operated and maintained to reduce total
paniculate 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 lime
Tor smelter roaster,  smelting furnace.
convener, or anode furnace process
  Existing controls in place at the
ASARCO-Tacoma amelter significantly
reduce the quantity of Inorganic arsenic
emissions from the arsenic trioxide and
metallic arsenic manufacturing
processes. Arsenic leden offgases from
the Godfrey roasters paaa through the
arsenic kitchens where arsenic trioxide
condenses on the walla of the chambers
and is collected as a product Cases
passing through the kitchens are vented
to a baghouae. The  temperature of the
gases at the inlet to the baghouse is less
than 121* C Offgasea 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 carloading 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
omissions to tevenl small baghouses.
These controls are in place at the
ASARCO-Tacoma smelter to comply
with PSAPCA arsenic and paniculate
regulations and with the U-.S.
Occupational Safety and Health
Administration (OSHA) inorgHmt
arsenic worker exposure standard.
  The composition of theMotal
paniculate matter emissions from the
33128         Federal Register / Vol. 48. No.  140 / Wednesday. |uly 20. 1983 / Proposed Rules
the OSHA worker expoiure standard.
Became BAT it already required in
order to comply with existing Federal
regulation*, additional itandarda bated
on BAT are not necciairy at thia time
for miacellaneoua aourcea of secondary
inorganic arsenic emissions at high-
arsenic-throughput smelters.
  The anode fumancea in operation at
the ASARCO-Tacoma amelter art of an
atypical design that la not used at
anyother primary copper smelter located
in the United Statea. Secondary
inorganic arsenic emissions (perheps up
to 0.1 kg/h) escape to the atmosphere
from a large opening in the anode
furnace wall. This opening allows the
furnance operators to perform activitlea
necessary for refining the bliater copper.
Secondary inorganic arsenic emissions
from the anode furnace could
conceivably be captured using an
elaborate secondary hood system.
However, the effectiveness of such a
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 aystem
designed to provide the necessary
access to the anode furnaces would
Impose very high costs. Based on the
email 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
•!•• determined that the existing
equipment represents BAT and. aa a
result, no standards are being developed
at thia time for secondary inorganic
arsenic emissions from anode fumacea.
  In summary, roaster, smelting furnace.
and converter process offgaaes aa well
as anode furnace, arsenic plant, and flue
dust handling sources art judged to be
currently controlled using BAT. Alao.
secondary inorganic emissions from
roaster calcine discharge, and smelting
furnace matte tapping and slag tapping
are captured and collected uaing 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, aa
a minumum. on BAT for secondary
emissions from converters.
Selection of BAT for Converter!

  Control Technology- Primary
converter hoods capture process
emissions  during converter blowing
periods: but. during charging, akimming.
holding, or pouring opera tiona. 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
methoda for capturing secondary
emissions from converter opere lions: (1)
fixed and retractable secondary hoods.
(2) air curtain secondary hoods, and (3)
building evacuation.
  Four domeatie smelters currently use
fixed secondary hooda to capture
converter secondary emissions. These
hoods are attached to the upper front
aide of the converter primary hoods.
More complex retractable secondary
hood designs are used at one domestic
smelter and smelters in Japan. Visual
observations made at two domestic
copper smelters showed that fixed and
retractable secondary hooda 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 converter secondary
emissions is the use of an air curtain
secondary hood.  Walls are erected to
enclose the sides and the back of the
area around the convener mouth. A
portion of the encloaure back wall ia
formed by the primary hood. Openings
at the top and In  the front of the
enclosure allow for movement of the
overhead crane cablee end block, and
the ladle. Edgea of the walla In contact
with the primary hood or the converter
vessel are sealed. A broad, horizontal
airatream blowe across the entire width
of the open span at the top of the
enclosure. This atrstream Is called en
"air curtain." The air curtain is produced
by blowing compressed air from a
narrow horisontal slot extending the
length of a plenum along the top of one
of the side walla. The air ia directed to a
receiving hood along the top of the
opposite side walL An Induced draft fan
In the ducting behind the receiving hood
pulls the eirstream Into the hood. When
the converter Is rolled out away from
the primary hood for charging.
akimming. 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 are then vented
to a collection device or released
directly to the atmosphere througn a
  The eir curtain secondary hood has
been demonstrated as an effective
method for capturing converter
secondary emissions. For the past 3
years, air curtain secondary hoods haw
been in place to control converter
secondary emissions at copper smeller-
in Japan. A prototype air curtain
secondary hood was installed in 1982 c
one of the conveners at the ASARCO-
Tacoma smelter.
  In January 1983. EPA conducted a tes
program designed to evaluate the
effectiveneas of the capture of
secondary emissions by the prototype
air curtain secondary hood at the
ASARCO-Tacoma amelter. The capture
efficiency of the system wes evaluated
by performing e gea tracer study and
visual observations. The gas tracer
study involved injecting e gas tracer
inside the boundaries of the fixed
enclosure and measuring the amount o:
the gas tracer in the exhaust gases in ir
ducting downstream of the enclosure
receiving hood. The capture efficiency
waa then calculated by a matenal
balance of the inlet and outlet tracer gc
maaa flow rates. Baaed on the results o
this test program. EPA believes en eir
curtain f scondary hood la capable of
achieving an overall capture efficiency
of 95 percent.
  Capture of converter secondary
emissions  by building evecuetion is
accomplished by controlling the eirflo*
patterns within the building housing ih
conveners end by maintaining a
sufficient air change or ventilation rate
Control of airflow in the ventilated are
ia obtained by isolating It from other
areas and by the proper design and
placement of Inlet end pullet openings
Proper location and siting of Inlet end
outlet openings provide effective airflc
pattema ao that the secondary emiesic
cannot escape to adjacent areas  or
recirculste within the area.
  EPA believes that a well-designed
building evacuation system should be
capable of achieving at leest  95 percer
capture efficiency of secondary
emissions. However, the building
evacuation systems currently used in
non-ferrous  metallurgical industry ha\
not demonstrated this level of control.
building evacuation system Is being
used at the ASARCO copper, lead, an
zinc amelter located in El Paao. Texas
to capture secondary emissions from
copper conveners and a zinc smelting
furnace operated Inside a building.
While preventing the venting of
secondary emissions to the ambient a
outside (he building, use of the buildir
evacuation system al the ASARCO-E.

                   era  Keguter  .  Vol.  48.  No. 140 / Wednesday.  July 20. 1963  / Propped  Rulea	3S12S
Pa jo smeller hai resulted in elevated
concentrations of inorganic arsenic.
lead and SO,, inside the building in
addition to excessive heat buildup. To
alleviate these unacceptable working
conditions, building openings have been
increased and roof vemrtlton 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
Hrsenic emissions is based on the
cooling of the exhaust gases to condense
(he inorganic arsenic vapors to form
paniculate*, and the subsequent
collection of the inorganic arsenic
particulars in a conventional
paniculate control device. Baghouse and
electrostatic precipitalor control device*
are currently used at primary copper
smelters to collect secondary inorganic
arsenic emissions as well aa paniculate
matter emissions.
  To evaluate the efficiency of a
conventional paniculate control device.
EPA tested the baghouse in place at the
ASARCO-EI Paso smelter used for the
collection of secondary emissions from
the conveners. Emission measurement!
for inorganic arsenic and total
particulars were conducted at the
bughouse inlet and outlet for three test
runs. At the baghouse outlet, inorganic
arsenic concentrations ranged from
0.01 S to 0.39 milligram per dry standard
cubic meter of exhaust gaa (mg/dscm).
The corresponding  total paniculate
concentrations at the baghouse outlet
ranged from  1.1 to 11.0 mg/dscm. Gas
temperatures at the baghouse inlet  were
less than SO*C (112'F). The Inorganic
arsenic collection efficiency wes 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 test runs waa 98 percent. EPA
concluded from the teats that • properly
designed, operated, and maintained
baghouse or  equivalent paniculate
control device can achieve a collection
efficiency of at least 90 percent for
inorganic arsenic.
  Regulatory Alternatives. To determine
the level of control that reflects DAT for
control of converter 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 II. For
 Regulatory Alternative I. no national
 emission standard would be established
 for inorganic arsenic emissions from
 high-anenic-lhroughput smelters. No
 additional controls 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 I 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 ia baaed on capture of the
 secondary emissions using a secondary
 hood consisting of a fixed enclosure
 with a horizontal air curtain. The
 captured secondary emlaaiona 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 242 Mg (311  tons) per year. In
 addition, there would be no energy or
 economic impacts associated with  this
   Regulatory Alternative D would
 reduce total inorganic arsenic emissions
 from the ASARCO-Tacoma smelter by
 110 Mg (121 tons) per year to a level of
 172 Mg (189 tons) per year. The •mount
 of collected paniculate matter
 containing Inorganic arsenic would be
 approximately 11 gigagrams (Cg) (12.000
 ions) per year. Thia would Increase the
 amount of solid waste generated at the
 ASARCO-Tacoma smelter from 182 lo
 193 Gg (201X000 to 213.000 tons) per year.
 an increase of about 8 percent. The
 additional aolid waste can be handled
 by the smelter's existing solid weate
. disposal system. Because the alternative
 is based on use of an electrostatic
 precipitator. a dry paniculate collection
 device, there would be no water
 pollution impact.
   The energy impacta of Regulatory
 Alternative II would be Increased
 electrical energy consumption. To
 operate the contra! system specified by
 the alternative, annual electrical energy
 consumption would be 1.5x10*
 kilowatt-hours per year (kVVh/y). Total
 smelter energy consumption is
 approximately 2.9X10* kVVh/y. Thus.
 Regulatory Alternative II would increase
 the total ASARCO-Tacoma elec'    '
 energy consumption by O.S per
   The capital costs for install!^
 control system specified by Regulatory
 Alternative II is S3.S 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 lo
 Financing. Even considering the
 possibility of additional capital
 expenditures for central equipment for
 the two ASARCO low-arsenic-
 throughput smelters (the ASARCO-EI
 Paso and Hayden primary copper
 smelters an addressed in Part IU of this
 preamble), it is EPA's determination thai
 ASARCO would be able lo obtain the
 necessary capital to install the control
 system at the ASARCO-Tacoma
 smelter. The ennualiied cost to
 implement Regulatory Alternative U is
 estimated to be S1J million. If ASARCO
 chooses to absorb the costa by reducing
 Ita profit margin, the profitability of the
 ASARCO-Tacoma amelter could be
 reduced up to 8 percent If ASARCO
 chooses to maintain its normal prof-
 margin and attempts to recover uV   u
 by inerecsing copper prices, the p
 increase would amount lo OS to 0.
   In summary, under Regulatory
 Alternative 1L total smelter raorg..
 arsenic emissions would be reduced by
 39 percent from 282 Mg per year to 172
 Mg per year. The reduction in emissions
 would be achieved with a small Increase
 in the amount of aolid waate generated
 at the amelter. There would be no water
 pollution Impact. Energy consumption at
 the amelter would be slightly increased.
 The primary economic impacta
 associated with thla alternative era •
 prelected modest decrease in
 profitabllty for the ASARCO-Tacoma
 smelter end a possible email increase in
 the price of copper. In EPA's (udgment.
 thla alternative would not adversely
 affect the economic viability of the
 ASARCO-Tacoma amelter or
• employment at the smeller. Because a
 significant reduction in inorganic
 arsenic emissions from the ASARCO-
 Tacoma amelter ia achievable with
 reasonable economic, energy, and non-
 air quality environmental Impacts. EPA
 selected Regulatory Alternative II as
   It should be noted that the level of
 control aelected aa BAT ia based upon
 the Adminstralor's best judgement and
 the information available el this tir-
 As discussed later, comments anc"
 information are being requested o.

Federal  Regular  /  Vol. 46.  No. 140 / Wednesday.  July  20. 1983  /  Proposed  Kules
additional control measure*. The final
decision on BAT will reflect
consideration of thate commentt and
may. therefore, include meaturea (e.g..
production eurtallfflenta or improved
operating and housekeeping practicei)
which are not now included in
Alternative II.

Contidention ofEmittion Reduction
Beyond BA T and Decision on Bom for
Proposed Standards.
  After Identifying BAT. EPA
considered the estimated residual health
nski and possible control alternatives
that would reduce emissions to rates
lower than 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-Tacoma imelter. Baaed on
epidemiological studies. EPA derived  a
unit risk number for exposure 10
airborne inorganic arsenic. The unit risk
number is a measure of potency
expressed ss the probability of cancer in
a person exposed to 1 ug/m • of
airborne inorganic arsenic for a lifetime
(70 years). Annual cancer Incidence (the
number of cases per year) associated
with Inorganic arsenic emissions from
•r-s ASARCO-Tacoma smelter is the
product of the total population exposure
around the imelter 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
•on 000 people living within about 20
kilometers (12.3 miles) of the ASARCO-
Tacoma smeller. For the current level of
inorganic arsenic emissions from the
ASARCO-Tacoma smelter, the annual
cancer incidence ia estimated to range
from l.l to 17.6 cases per year. With
BAT In place at the ASARCO-Tacoma
imelter 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
continuousl| exposed during a 70-year
period to the maximum annual inorganic
arsenic concentration due to Inorganic
arsenic emissions from the ASARCO-
Tacoma smeller.
  All known control alternatives were
examined with the particular emphasis
on the further contol of secondary
                        emissions, which on the bans of
                        modeling remits, 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 (span 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: (1) production
                        limitations or curtailments and (2)
                        limitations on the smeller inorganic
                        arsenic throughput.
                        Impact! of Control! Beyond BA T
                          Without specific and detailed
                        knowledge of all economic information.
                        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 imelter 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 23 percent. Thus.
                        while further curtailments may be
                        possible, it is doubtful that the degree of
                        curtailment necessary to significantly
                        reduce risk (e.g.. a 30 percent additional
                        curtailment would reduce the estimated
                        maximum risk from a range of 0.36 to 9.2
                        in 100 to a range of 0.29 to 4.6 in 100)
                        would be affordable.
                          An analyaia of the importance of high-
                        inorganic-arsenic feed to the economic
                        viability of the  ASARCO-Tacoma
                        smeller leads to the conclusion that the
                        smeller would probably close if high-
                        inorgsnic-arsenic-contact materials
                        could not be processed. High-inorganic-
                        arsenic-content copper ore concentrate
                        and lead smelter by-products represent
                        about one third of the feed materiel
                        input to the ASARCO-Tacoma  smelter.
                        If forced to discontinue use of these feed
                        materials. ASARCO would need to
                        compete with other copper smelling
                        companies for additional supplies of
                        copper ore. In the face of fapanese
                        competition and currant copper ore
                        shortages, it la  questionable whether
                        sufficient supplies of low-arsenic-
                        content copper ore concentrate could be
                        obtained at prices that would allow
                        profitable optiration. Mora Importantly.
                        the use of high-inorganic-arsenic feed
                        allows ASARCO to produce arsenic
tnoxtde and metallic arsenic. EPA
estimates that (he sale of arsenic
tnoxlde and metallic srsenic represents
about 10 to 13 percent of the ASARCO-
Tacoma smelter's total revenue and
could account for most of the profit.
Therefore, for purposes of this analysis.
EPA is concluding that any potential
meens 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 smelter supplies
about one third of the total nationwide
demend for arsenic. The remaining two-
thirds is imported and represent! over
helf 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 23 percent to makeup the
shortage. It is considered doubtful  that
such an increase would be possible ever
with substantial upward price pressure.
The impect that this shortage would
heve on industrial producta-(e.g..
pressure treated lumber) and
agricultural uses (e.g.. cotton desiccants.
herbicides) has not been estimeted.

Consideration cf Health Risks

  As deteiled in Section I of this
preamble, the estimated health risks
cited above associated with exposure 10
ambient inorganic arsenic are at best
only a very crude estimator of the  aciua
health effects. The 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 ere high
relative to other Inorganic arsenic
sources and to other sources of
heierdous 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 safely.
Moreover, direct emblem 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) haa been
proposed as a National  Priority List Sin
by  EPA under the Superfund program
(47 PR 36476. December 30,1962).

                eoerai   syster  /  vol. 48. No. no /  Wednesday. July 2u. 1963 / rroposeo ivuies
 Consideration of Impacts of Beyond

  Closure of ths ASARCO-Tacoma
 smelter would result In severe social
 and economic impact on the local
 economy. Moreover, since the
 ASARCO-Tacoma smelleMs the only
 domestic smelter capable of smelting
 high-impurity copper ores end
 production of associated by-products
 including arsenic, closure of the smelter
 would result in a total loss of this
 domestic production capability. Closure
 of the smelter would eliminate the Jobs
 of about 500 ASARCO employees and
 300 additional jobs in the Tacoma area.
 Closure would also mean elimination of
 S20 million per year in revenues to local
 companies and S2 million per year in
 State and  local taxes.

 Decision and Proposed Standards
  As detailed in Part I of this preamble.
 under EPA's interpretation of Section
 112. the smelter should be controlled at
 least to the level that reflects BAT and
 10 a more stringent level  if necessary to
 prevent unreasonable risks. The
 decision as to whether the remaining
 risks are unreasonable Is based upon
 consideration of the Individual and
 population risks and consideration of
 the  impacts, including coats, 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 at ASARCO-Tacoma may be
 umcasonable. 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 alternatives was 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 thsn 0.7 percent Inorganic arsenic
in the total smeller 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
smelter. This would reduce the smeller
contribution to the estimated health
risks to zero: but would also result in a
loss of lobs, 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 basis for a decision
to require beyond BAT controls and. in
this case, possibly cause closure of the
ASARCO-Tacoma amelter. the
Administrator believes it Is necessary to
scrutinize 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 la Part I of this
preamble and Appendix E of the BiO.
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 that a linear reletionshlp
exists between cancer risks and level of
exposure and this relationship Is the
same at the low levels of public
exposure aa at the high levels of
occupational exposure. There 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 la evaluating
environmental hazards. Because Its
scientific basis, although limited. Is the
beat of any of the current mathematical
extrapolation models, the linear
nonthreshold model has been adopted
here as the primary basis for risk
extrapolation at low levels of exposure.
Additional assumptions made in the
determination of the unit risk estimate
era that all people era equally
susceptible to cancer and that persons
are exposed continuously from birth
throughout their lifetimes (70 yean). The
Administrator believes that the
assumptions made la 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 unil risk would be much
 more then (he eslimated unil risk, but it
 could be considerably lower.
  Uncertainties In the ambient mo
 exist due to the limitations of the
 dispersion model and the assumptions
 and potential error in the dels Input to
 the model. LJmitslions in  the model
 include Its Inability to account for the
 variable operating conditions of the
 smeller end variable meteorology: that
 is. one set of operating and
 meteorological conditions wss assumed
 for modeling purposes. The
 meteorological conditions used are
 believed to be representative. However.
 the smelter operating conditions used  in
 the modeling do not eccount for the
 frequent curtailment of operations now
 required at ASARCO-Tacoma to reduce
 emissions of sulfur dioxide, and
 therefore, probably result in sn
 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 la the area.
  la addition, then were many inputs to
 the model such as location of each
 emission source at the smeller and the
 rate, temperature, and height at wh»'L
 those emissions era released to thr
 atmosphere. Each of these Input
 parameters is sub|ect to error, but
 perhsps the most crucial parameter is
 the estimate of emission rates. The
emission rales used by EPA were based
on actual emission test data whenever
possible. However, for some sources.
most notably converter secondary
emissions, test data wen not available
 at the time the estimates wen made:
 therefore, some assumptions were made
 for modeling and impact analysis
 purposes. The EPA assumed, for
 instance, that converter secondary
 inorganic anenic emissions wen
 approximately IS percent of those
 measured In the primary converter
 offgases. Preliminary results of testing
 conducted in January 1983 on converter
 No. 4 at ASARCO-Tacoma indicate that
 emissions may be significantly less than
  Additional uncertainties erise 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 estiir
 smbient air concentrations  is not k

Federal Register /  Vol.  48; No.  140-/ Wednesday.  July 20. J983 / Proposed  Rules
and the relative location! uied in the
eipowre model have changed since (he
1970 census. In addition, it is assumed
that people remain in the seme location
for a lifetime (70 years), the only
exposure of the population that occurs is
due to the ASARCO-Tacuna smeller.
and only persons within 20 kilometers of
i he emission source ere effected.
  In summary, then is a high degree of
uncertainty m the estimated health risks
due to the many assumptions and
uncertainties associated with the
components of the estimetes. While the
estimated  risks may 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 area
show significantly lower ambient
concentrations of inorganic arsenic than
those predicted by the model, and  (2)
data on lung cancer incidence rates for
(he ten largest cities in Washington for
the years 1970 through 1979 show that
Tacoma ranks filth, and the lung cancer
rates 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
senous negative impacts associated
with closure, and the absence of
comments from the affected public, the
Administrator cannot conclude at this
time thet the risks remaining after  the
application of BAT era unreasonable.
Therefore, standards are being proposed
for the category of high-arsenic-
                            no.  /
                                                         eanesaay.   uiy  ..c.  iaw  /  Proposed Rules
 morgsmc-srsenic-contenl ore
 concentrate hat the potential for higher
 inorganic arsenic emissions than a low-
 concentrate. The ASARCO-Tacoma
 smelter is a custom smelter processing
 ore concentrates shipped (torn 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
 smelter. Thus, (he 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 for inorganic arsenic
 based on a  mass emission rate, 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 (or the ASARCO-Tacoma
 smelter based on currant data might not
 require application of BAT is other ore
 concentrates were processed. In
 contrast, a percent reduction format
 would require the application of BAT
 regardless of the level of inorganic
 drsemc content in the feed materials.
 However, high collection efficiency may
 noi oe continuously achievable for the
 pnnre range of inorganic arsenic
 concentrations which could occur in the
 captured gas streams from the
 secondary emission sources.
  As an alternative, an emission limit
 fur total partieulates that reflects the
 level of control device performance
 necessary to achieve BAT for collection
 of secondary inorganic arsenic
 ^missions can be developed. There are
 several advantages le using a total
 pjrticulale 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 use of
 BAT for all  high-arsenic ore
 cnncentrates regardless of variations in
 the inorganic arsenic content of the feed.
The second advantage to a 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 partieulates. 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
  Mass 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 partieulates
 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 r»oth
 uncontrolled and controlled emissions.
The measurement of emissions at the
 inlet :o control devices poses testing
 difficulties due to 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 formal
 would limit total paniculate emissions
 per unit of copper produced or smeller
charge. Determination of compliance
 with a mass per production unit
 standard requires the development of«
 material balance or production values
 concerning the operation of the copper
 smeller. Development of thia
 information depends on the availability
 and reliability of process data provided
 by the company. Gathering these data
 increases the testing and reeordkeepin*
 requirements and. consequently.
 increases the compliance determination
  A concentration formal would limit
 total paniculate emissions per unit
 volume of exhaust gases discharged lo
 the atmosphere. Compliance
 determination of concentration
 standards requires a minimum of data
 and Information, decreasing tha costs 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 discha-
 to the atmosphere with excess air. tl
 lowering the concentration of total
 particulars 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 lower 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
Sr/n-fimi nf \umrrial Emi.tsinn Limit
tin ri Kifuifimffiti Specifications

  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 secondacy
emissions  from convener*.
  The formal selected for the proposed
 standard for capture of secondary
 inorganic arsenic emissions from
converters consists of equipment and
 work practice specifications. EPA
 believes that the prototype secondary
 hood design installed on converter Nv
at the ASARCO-Tacoma smeller 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 lo variations in
 convener configuration and space
 availability. EPA choae not lo specify
 physical dimensions for the hood
 enclosure. Instead. EPA decided to
 specify the design practices that are
 necessary to follow in order lo obtain a
 secondary hood system capable of
 achieving at least a 95 percent capture
 efficiency. These design practices are:
 (1) the configuration and dimensions of
 the hood enclosure ore sized so thai the
 converter  mouth, charging ladles.
 skimming  ladles, and other material
 transfer vessels are housed within the
 confines or influence of the hood durir

Federal Rtfi*tw /  Vol.  48. No. 140 / Wednesday.  |uly 20. 1983 / Proposed Rules
each mod* of converter operation: (2)
the back of the hood enclosure la fully
endoaed and sealed againat the primary
hood (3) the adfn of the hood enclosure
tide walls In contact with the converter
   •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 (he entry snd
egress of ladles and crane apparatus is
minimized to the fullest extent practical:
•nd (S) 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 ia produced by
blowing compressed elr 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
(his slot and the velocity of the air
blown through the slot ere essential
design parameters for determining the
momentum of the air curtain. Sufficient
air curtain momentum must be
maintained to prevent emissions ruing
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 22J70 watts (30 air
horsepower) at the alot.
  After installation of an air curtain
secondary hood system, the owner or
operator would be required to operate it
•t conditions optimum for the capture of
secondary inorganic arsenic emiesions
(see "Optimisation 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. Baaed on
these observations. EPA concluded that
the work practices followed by the
individual converter and crane
operators can significantly impact the
amount of secondary emissions that era
captured by the secondary hood system.
To assure the 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)
an curtain and exhaust flow rates shall
br increased by the converter operator
                        to optimum conditions prior to raising
                        the primary hood and rolling the
                        converter out for skimming: (2) once
                        railed out. the converter operator shall
                        hold the converter in an idle position
                        until fuming from the molten bath cesses
                        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 converter to minimize the
                        drop distance between the converter
                        mouth and receiving ladle: (4) the rate of
                        (low into the receiving ladle shall be
                        controlled by the converter operator to
                        the extent practicable to immunize
                        fuming: and (5) upon completion of a
                        charge, the crane operator shall
                        withdraw the charging ladle from the
                        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). and (4) above. The public ia invited
                        to comment on the need to specify
                        minimum times to be aasociated with
                        the proposed work practice standards
                        ens on what times may be appropriate.
                          ASARCO has elated it intends to
                        install air curtain secondary hood
                        systems (similar to the system already
                        in place on converter No. 4) on its
                        converters that will remain in service at
                        the Tacoaa 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 ia not intended to preclude
                        the use of other aecdndary inorganic
                        arsenic capture systems which may be
                        as effective ae 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'a
                        satisfaction to be equivalent in terms of
                        capture efficiency for inorganic arsenic
                        may be approved (aee "Equivalent
                        Systema for the Capture of Secondary
                        Emissions from Converter Operatt>  .is"
                        in Part 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 teat results for the
                        control devices Judged to represent BAT.
                        The test results were  discussed in the
                        Control Technology section of this part
                        of the preamble. These results consist of
a series of three consecutive sample
runs for which the measured total
paniculate matter emissions at the
control device outlet ranged from l.l
11.6 mg/dscm. The average value for
three runs was S.I mg/dscm. The res
show that a control level of at least l
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 Emisai
from Stationary Sources" In Append)
of 40 CFR Pan 60 would be required '
determine compliance with the
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 performsnce 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 Gas Velocir
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 Dn
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 Requinmen

  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 aa to be accessible
  The performance of the equipment
used to capture the secondary emiss
from the covener operations is high!-
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 continur
monitoring of the time and air flow r
through the air curtain systems, and
keeping e log of times for each of tku

                     c»u«y. juiy
                                                                                / rroposeo rune*
 converter operations. Thii would allow
 (he correlation of recorded gai flow
 rates with the corresponding converter
  To help the Administrator determine
 whether each secant-ary hood system is
 being properly operau*! 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
 i ha i correspond to each converter
 operating mode while the secondary
 hood system is operating under optimum
  The proposed standards for the
 collection of secondary inorganic
 artenic emissions are based upon a total
 paniculate concentration limit. One
 alternative to monitoring the
 performance of the collection  device is
 to periodically test the collection device
 using Method 5. However, this
 alternative is costly and ia not
 considered reasonable. Continuous
 monitoring of opacity or en operating
 parameter of the collection device may
 be used to indirectly monitor
 performance by indicating whether or
 not the collection device ia operating in
 the same manner as when it
 demonstrated compliance during the
 emission test. Of these two alternatives.
 monitoring opacity ia simpler to apply.
 Therefore, the monitoring requirement
 selected for the collection of secondary
 b. ....lie emissions is to continuously
 monitor opacity uaing a
  To implement this monitoring
 requirement it would be necessary to
 establish • reference opacity level
 against which future performance of the
 control system could be compered. 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 the opacity level
 would be established et the 97-5 percent
 upper confidence level of • normal or
 log normal (whichever  is more
 representative) distribution of the •>
 minute average opacity values. This
opacity value would be the baais 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

  II 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 as
in the case of fan horsepower capacity.
and more general for others, such as the
dimensions of the secondary hood.
Some of the requirements ere general
because unless there are any new
smelter*, which is considered unlikely.
each Installation will be a retrofit that
is. eech eir 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 smelter.
  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 are
adjustable in the sense that they can be
altered in a relatively short time and at
relatively email coat It is expected that
after the initial installation of each air
curtain secondary hood system, there
will be • "shakedown" or optimisation
period during which the proper balance
of system parameter! will be determined
for eech particular Installation.
  For every air curtain secondary hood
installatioa there will be aa optimum
set of operating conditions, beyond
which further "One tuning" of the system
will not result In Increased capture
efficiency. Section 112(e)(l) of the Clean
Air Act state*; In part that If the
Administrator promulgates a design or
equipment standard, "ha shall Include es
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 an air curtain secondary
hood system include* operating the
system es close to optimum conditions
as passible, end the owner or operator
would be required to do so under the
proposed standards. It is not the
Administrator's latent however, to
require the owner or operator to operate
a system beyond optimum conditions
(i.e.. at flow rate* and power
requirements that do not achieve
additional capture) or to prevent
operational change* that may not.
the capture efficiency of the system.
  Authority for determination of the
optimum condition* far each air curtain
secondary hood system metalled to meet
the proposed standard* would rest with
the Administrator. Due to the variable*
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 condition* for each air curtain
secondary hood installation. Obfective
techniques, such a* the tracer study
used to evaluate the air curtain
secondary hood system on the No. 4
converter et the ASARGO-Tecomo
smelter, era available to help determine
capture efficiency. However, a final
determination of whether a system has
truly been optimised, or If not whet
steps should (or could) be taken to
improve It will largely be a .matter of
  One approach the Administrator la
considering as a method for determining
optimum conditions for each air curtain
secondary hood installation would be to
have each system evaluated by a pa*»i
of persona with expertise in assess
visible emissions of air pollutants.
panel  could be comprised of 3 or mo..
persons, including representatives of
industry. EPA and local air pollution
control tigftnoM*
  The panel would evaluate each air
curtain secondary hood a* follow*: (i)
the panel would review the plan* and
specification* of the system prior to
installation (2) the panel would agree
on initial operating condition* for the
system: (9) the panel would observe the
operation of the system during each
mode  of converter operation under the
initial operating conditions. Estimates of
the capture effectivenee* achieved.
based on visual observation*, would be
recorded by each panel member for
eech mode of operation. In addition.
comments on the minimum and
maximum capture effocthrenes*
achieved, the duration, location end
density of visible emission* observed.
and a  qualitative assessment of the
volume of the emiaaiona escaping
capture (e.g, light moderate, heavy.
etc.) would be recorded: (Abased on
this initial evaluation, the panel would
agree  on what modifications would be
needed to further optimise the operation
of the air curtain secondary hood: an-'
(5) the panel would again view the

              Federal Register /  Vol. 48. No.  140 /  Wednesday. |uly 20. 1983  /  Proposed  Rules
system (as In 3) after modification 10
compare its performance lo pre-
modincatien performance. After this.
steps 4 end S would be repeeted es
needed until there wee agreement
among the panel members that the
system hed been optimised. The panel
would then recommend a sal of optimum
operating conditions for thai system to
the Administrator along with  -
documentation of their evaluation. In the
event of disputes, panel members would
submit separate recommendations. The
Administrator would meke e final
determination of the optimum conditions
based on the panel's recommendetion
end supporting documentation.
  If. subsequent to e doterminetion that
a system haa been optimised, en owner
of operator proposes to make an
additional modification to the system.
the panel would egeln be convened end
would observe the system both before
end after the change as prescribed in (3)
above. The modification could bo
approved by the Administrator if the
panel found It did not reduce capture
  The Administrator believes this
approach would assure that the eir
curtain secondary hood system is
designed end operating conditions
esteblished which will minimise
secondary Inorganic arsenic emissions
to the greetest extent possible, but
would also allow the owner or operator
to make modifications to the system  that
would not reduce cepture efficiency.
The public Is Invited to comment on the
need to eveluete the optimisation of
each air curtain secondary hood system
••"I on the penel approach being
considered by the Administrator.

Reporting and Reeordkeepiny
  Owners or operators of sources
covered by the proposed standards
would be subiect to the reporting and
recordkeeping requirements of the
proposed standarda. aa well as those
prescribed In the General Provisions
(Subpert A) of 40 CFR Part 61. Under
161.10 of the General Provisions, an
initial report from each existing source
Is required to be submitted within 00
days of the effective date. For purposes
of determining Initial applicability, the
proposed standards for I
throughput smelters specify that the
Initial report required In |61.10(a) will
include information on 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
totel smeller charge be made end that
the monthly computetion of e rolling
annual average of the inorgenic ereeniic
content of the total smelter cherge be
mede and that the monthly
computations be recorded and dept on
site for at leest 2 years: The monthly
compulsions would neve to be reported
to EPA on en ennuel basis to ensure thsi
applicability with respect to the
standards had not changed.
  Under Section 114. EPA is authorised
lo establish reporting requirements to
determine whether there ia a violation of
standards proposed under the Clesn Air
Act. Concern es to whether the systems
for the control of inorgenic arsenic
emissions are continuing to meet the
proposed standarda would primarily
arise when monitoring showed opacity
levels In excess of those determined
during the compliance demonstration or
eirflow rates thet vary significantly from
those established during the
optimisation procedure. Therefore, in
determining the necessary reporting
requirements, it wes 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 compsntes collect
any of this Information. In addition
there ere no reporting requirements by
other govemmentel egendes for this
type if information which would result
in overlapping data requirements. The
types of Information to be included in
the reports are diacuaaed below.
  For the converter secondary hood
system, each semiennual report would
indicate: (1) the reference airflow rales
esteblished for each converter
operational mode, and (2) • recotd of
eirflow rates for each  day when the
eirflow rates are leas than 20 percent of
the corresponding reference values.
  For the collection devices for
secondary emissions, each semiennual
report would provide (1) e record of
trensmlssemeter readings for each day
on which the opadty exceeded the
reference opadty limit determined at the
time the collection device demonstrated
compliance, and (2) the values of the
emission test opadty limita.
                                                                           Office of Management and Budget
                                                                           (OMB) approve reporting snd
                                                                           recordkeeping requirements thsi qualify
                                                                           es en "information collection request"
                                                                           (ICR). For the purposes of
                                                                           accommodating OMTs review. EPA
                                                                           uses 2-yeer periods in its impact
                                                                           analysis procedures for estimeting the
                                                                           labor-hour burden of reporting end
                                                                           recordkeeping requirements.
                                                                             The average annual burden on high-
                                                                           arsenic-throughput copper smellers to
                                                                           comply with the reporting end
                                                                           recordkeeping requirements of the
                                                                           proposed standards over the first 2
                                                                           years after the effective dele  is
                                                                           estimated lo be 1J10 person-hours.

                                                                           Regulatory Flexibility Analysis

                                                                             The Reguletory Flexibility Act of 1980
                                                                           (RFA) requires that differential Impact*
                                                                           of Federal regulations upon small
                                                                           businesses be Identified end analyzed.
                                                                           The RFA stipulates thai an analysis is
                                                                           required if e substantial number of small
                                                                           businesses will experience significant
                                                                           impacts. Both measures must be met:
                                                                           that is, a subsiantlel number of smsll
                                                                           businesses must be effected end they
                                                                           must experience significant Impects. to
                                                                           require en enslysis. Twenty percent or
                                                                           more of the smell businesses in en
                                                                           effected industry  is considered e
                                                                           subslentiel number. The EPA definition
                                                                           of significant impact involves three
                                                                           tests, es follows: (1) prices of products
                                                                           produced by small entitles rise 8 percent
                                                                           or more, essumlng costs are passed on
                                                                           to consumers: (2)  ennuellsed  Investment
                                                                           costs for pollution control are greater
                                                                           than 20 percent of total capital apendlng:
                                                                           or (3) costs as a percent of aales for
                                                                           small entities are 10 percent greater then
                                                                           costs as a percent of sales for large
                                                                             The Smell Business Administration
                                                                           (SBA) definition of a small business for
                                                                           Standard Industrial Classification (SIC)
                                                                           Code 3331. Primary Smelting and
                                                                           Refining of Copper., la 14)00 employees.
                                                                           The ASARCO»Tecoma smelter Is owned
                                                                           by e company that has more than 1.000
                                                                           employees. Therefore ASARCO does
                                                                           not meet the SBA definition of e smell
                                                                           business and  thus no regulatory
                                                                           flexibility enalyais la required.
                                       EPA believes that these reporting end
                                     recordkeeping roqulramenta are
                                     necessary to assist the Agency In (1)
                                     identifying sources, (2) observing the
                                     fompllinft testing and demonetretion of
                                     monitoring devices. (3) determining
                                     initiel compliance, end (4) enforcing the
                                     standard after the Initial compliance
                                       The Peperwork Reduction Act (PRA)
                                     ..   «(Pub. L 06-611) requires thet the



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

Smelter    battle
   Politics,  economics  and  environmental  issues
   are whirling around  the Asarco  controversy
A-i4 Tacoma, Sun., July 17,  1983, The News Tribune
 Smelter    battle
 (Continued  from
  orecedlng  page)
  He said Asareo  officials are
scheduled  to discuss this  week
what presentations  the company
will present to the EPA.

   As in the past the theme, but-
     tressed by testimony from
doctors  and university research-
ers, is expected to be that smelter
emissions do not harm people. At
the 1981 variance hearing, Asareo
hired the Seattle public relations
(inn of Hill and Knowltan to baa-
die publicity.
  Additionally. Asareo is likely to
emphasise the good the smelter
does in the area. It employs seme
S70  people, baa a  muld-imlUoo
payroll, pays
large purchases on the local i
  There are some mm
           Asareo to
           of arsenic IB the
'Tnited States.
others who use arsenic in their
products would Incur higher earn
if they had to purchase the metal
in foreign countries which don't
have to pay for expenane  pollu-
tion controls. Undquist said.
  Brian Baird. a member of Taao-
     f or a Health)
                              • I  hope it will be decided on the scientific
                             merits  of   the  case.   I   think  emotional
                             appeals will  be made,  based on emotion
                             alone. This  is  inevitable  in something like
                             this, y
                                                                   — Larry Undquiat
                                                              Aaarco omotter manager
                                   "I am
                            the way in which public opinion a
                            shaped often by the party with the
                                        i of money."
                                             don't  have
                                                                    ij^ •» •
                                                                    EOT • IBUK^KflK
                                                         of the smelter.
                                                          "I don't believe anyone is seek-
                                                         ing total closure of the mill." said
                                                         Dong Jaekmaa. of the Washington
                                                           Baird saioVW». will sand for
                              Baird said the
                            wintry to
                            dal might by
                                      Uka the
                                  i the public and get proper
                                  nation at t
                              "We may have
(THE), said he is a
about the kind of *"»«p"sji Asar-
eo may wage,
  "Tacoma is setting a
(in EPA policy) and it is i
ceivabl* Asareo would launch a
publicity campaign, and publicize
distorting  (acts or ' ~
that suits their
  He said he is
issue could
or public  relations
ratter than a health and
to highlight the tssoe£BaJrdiaid.

     _..' win aba be reviewing
     ! and EPA castrisk benefit
     t to prepare fflr the bearing.
       PA • expected to provide

    ' data en the bane to the Ta-
                                                              net appear Asareo will be
                                                         able to meet that.
                                                           "ITs time for Tacoma to change
                                                         id image. Instead of covering (or
                                                         theae guys Uka Asareo. it should
                                                         try to bring in new Industries to
                                                         take the place of the polluters.
                                                         .  "We want Tacomc to be able to
                                                         employ people without killing peo-
                                                           Baird also suggested that the
                                                         smelter and the publicity it has
                                                         been receiving could hurt conven-
                             deaaea aaaueBUkjA^^h aT^kv e)tk^ Bk^bM^B^hM — —
                             CUB prepare lor me Bearing, ac-
                             cording to Bob  Jaeobsoa. a
                                    i (or the EPA.
                                     tactic of the
                                                         the city hopes the Tacoma Dome
                                                         win attract.
                                                           Conversely. Baird said  his or-
                                                         gSBJiaiiM doesn't want ttn> word
                                                         to go out that Tacoma
                                                         are willing to take risks with their
                                                         health.      V-..
                                                        _"lf every company leans Taco-
                                                         mans are willing to die (or em-
                                                         ployment, the the aggregate effect
                                                         can be unacceptably large." he
   Lindquist. the smelter
      ger. has a similar «	
  "I hope it will be deeded on the
scientific merits of the case." be
said.  "I think emotional appeals
  !11 be made, based on emotion
  .ne. This is inevitable in some-
taing like this."
  Re said smelter employees have
already beard one ptrttm rail a
radio talk show and complain it
smelled as  though Asareo  was
"frying dogs."
  On  the other side. BaM mm.
                            bavet traditionally stood solidly

                            on the environmental issues. The
                                                           Baird also hopes national dean-
                                                         air groups will become involved in
                            in the past by i
                              "For too  long, the industrial
                            community has been playing the
                            two groups (environmentalists and
                            labor) against each other." said
                              An effort likely will be made to
                            convince labor leaders that "the
                            net effect of pollution controls is
                            the creation of Jobs." Baird said.
                              Perhaps in an effort to recruit
                                                           This is  a precedent-setting
                                                         ease." be said. "It has never been
                                                         put in the lap of the community
                                                         before to say how much risk it is
                                                         willing to take. So it is very im-
                                                         portant for national groups to get
                                                         together." Baird said.
                                                           Dale Jones, director of field of-
                                                         fices for the Seattle Office  of
                                                          Continued on Page A-15

'Taconia, Sun., July 17,  1983. The News Tribune

   AS2irCO   From Page  A-14
   Friends of the Earth, guessed that
   environmental  experts won't be
   brraght  in (ram New York and
   Washington. D.C, to testify in Ta-
     He ""* Rnckelshsus'  proposal
   that the pablie help define the ar-
   senic nsk It will accept is a -trial
   balloon that has already bant."
     Jones «•"* that if RuckeJshaos'
   decision was in any way based on
   a "public opinion poiL it wouldn't
   stand op in the coons."
     Barnes, the regional  EPA ad-
   ministrator in  Seattle,  has said
   public input will be "extremely
   important" in the decision-makinc
      Jones said that if Ruekelshans'
    proposal was valid, it would mean
    that people in the industrial Ohio
    Valley would be helping to make
    decisions about aod rain caused
    by thihr industrial plants that falls
    in N«w England.
      The law require that the deci-
    sion be based on the EPA'sprovid-
    ieg a -margin of (public) safety,"
    he said.
      "If  (Ruckelshaus)  wants to
    change the law.  he has to  go to
    that the EPA must be careful of
    the grounds on which it makes its
    decision on Aaarco'i «nniTtiom
      "The Clean Air Act does not in-
    clude cost as a criterion for devel-
    opment   of   hazardous   air
    pollutants  (controls)." said Jack-
    man.  of the Washington Loaf As-
      Ruth  Weiner. chairwoman  of
    the Cascades Chapter of the Sierra
    Club, said  she thought  Ruck-
    elshaus was attempting to make it

    sue" without really trying to ex-
    plore what  new  technology  is
    available  to control the arsenic
    emissioos a
 Smelter  letters:
 IK* M»«n lil»«M	

  SEATTLE - By • tuft niter-
 Mr. pt«*l* •f||fa| Ik* EmlrM.
 Riinlil ProUcIlM AiMcy U
 rommm M UM Aim* mrilcr
 •••I cracn e*«ta| *nnlc
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 Uvto Krai. •• EPA *flkhl
icllaf M • nortftoitar far Ito
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rcrdnd *M Uliylm  oil  to
•kick • perm uM l*r tofarnM-
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  ••I • nkMtUy *l  •illm MB
   Many of 71 who have written EPA urge stronger requirements

   for arsenic emissions; some ask closure; others offer support
 rw • k*| to M* |tM* d kklk  M. *f •••! Itort* t VukM to-   M*n*lIk*nwlUf oWc*«*4 *^*"«

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                                            •Mpto *•*• MfaMb to **toiMto* Ikto to yMally wlilr MA I to
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                                                                       II III I'M
         to totof MkH I*
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  tidt't l« Mmde. Ik* pro-
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 Hi* MM ErtcUoa *f 1111 •.
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 _) Ito illtoml cNltm ckMM
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M»»Ml»y»m< *i H to n* blot
«rt •• r«mr b Itol *0 *f •

PRO:    Many   Rustonites
 cite   smelter's   benefits
  RUSTON - "Balooey."
  This epithet spoken politely but
firmly was Owen T. Gallagher's
considered opinion of the Environ*
mental Protection Agency's warn-
inp this week aboot the hazards
of living in tat  shadow of tae
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
thtn 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 the goose
that  laid the golden egf." said
Gallagher, seated in his neat brick
home just  five blocks  from the
   elter gate.
   fbe smelter, the town and its
residents, he said, hare enjoyed a
mutually comfortable relationship
for more than 90 years.
  Gallagher well knows how the
three are  intimately connected.
The lives of Gallagher, the Asarco
 smelter and this  town near Point
 Defiance Park are intricately in-
   Gallagher was  bora here on
 North Winnifred  Street, four
 blocks from the  smelter gate.
 more  than 70  years  ago. He
 worked for Asarco for 43 years.
 starting as a laborer in the copper
 smelter and retiring  five years
 ago as personnel manager.
   Gallagher is a legend in town
 politics. He founded the volunteer
 fire department. He served on the
 Town Council for 15 years. He was
 mayor for 20 years before step-
  ping down two years ago.
   During his years of  public ser-
  vice, said Gallagher. Asarco was
  good for Ruston and  its  people.
  The smelter provided as much as
  70 percent of the  town's  budget.
  furnished steam to beat the Rus-
   n Elementary  School and hand-
   .mely paying jobs to support a
  number of  its residents.
   Environmental restrictions that
  could threaten the smelter's very
  existence, said the former mayor.
  are "just a bunch of foolishness."
   Living by the smelter does pose
                              Owen Gallagher
                                said, bat the benefits far outweigh
                                 Just recently, be said, after the
                                smelter restarted its furnaces that

                                threat of a strike that didn't mate-
                                rialise, the area wa* hit with a
                                sootv fallout It landed on can in
                                Rnstoa and oa boats at the nearby
                                      i Yacht dub.
                                 "All yoBTt got to do is go oat
                                and give yovr car a quick wash,"
                                he said. "If yoa leave it  oa,  it
                                    ; eat into the paint."
                                              of any damage.
                                "The smelter has painted a lot of
                                can over the yean," ha said.
                                 The payoff far the "Inconveni-
                                ences," at said, art lower taxes
                                and better city strrtets than in
  Til tee •eekly  garbage service
here is free, he said. With the ex-
ception of a single street all of the
town's alleys and  streets  art
paved without tat need for local
residents to pay for them directly.
The town employs a seven-mem-
ber (two fall-time sad five part-
time) police force,  a relatively
large force for a town of Ruston s
sue. he said.
  More threatening than the soot.
the EPA said, is the 310 tons of
airborne arsenic the smelter em-
its each year.
  Gallagher dismisses  arsenic
emissions, too.
  "When you're  in a bakery, yoa
expect to get some flour on yoa.
he said.
  While the smelter's chief arsen-
ic-containing byproduct arsenic
trioxide. bears an uncanny resem-
blance to cake  flour, it* •
art not nearly so benign, said the
  The arsenic emitted  by  the
smelter, the EPA estimated, caus-
es an additional  four  cancer
deaths yearly ia the Tacoma met-
ropolitan ana.
  If EPA Administrator William
Rnckelshaas adopts his proposed
arsenic limitation roles, those ar-
senic-related cancer deaths' ia the
Tacoma area an expected to drop
  Bat Rackelsaaas. ia the first
test of his new regime at the
battled agency, has asked
touched by the smelter's
emission* to tell him if his pro-
posed standards reprum an ac-
ceptable risk leveL
  A hearing is set for Aug. 30 ia

  If Gallagher and other Ruston
tow* officials an typical.
maay may speak oat against <
farther  restrictions that could
dost the  S70-employee smelter
and cot off its annual 123 million
  Mary Joyce and her husband
have  raised their six children fig-
uratively ia the smelter's back-
  Her home's picture  window
neatly frames the smelter's 5*0-

29 feet shorter thaa Seattle's
Space Needle.
  Her homf s elevated front yard
is landscaped with chunks of  the
Ma«* obsidian-like slag from the
  Joyce,  a town councilwoman,
said she knows of only one family
among Rostoa's  population that
has made any strong protest about
                                                               Those who art bothered by the
                                                             smelter's •"»*••*«'••• she said, ei-
                                                             ther don't boy ia Raston or they
                                                             move away.
                                                               "I think that if anyone felt that
                                                             strongly  about it, they would
                                                             move. A person shouldn't have to
                                                             live ia a community if they're not
                                                             happy with it" sat said.
                                                               Raston Mayor Peter Brndevold
                                                             believes the populace  here would
                                                             agree with him that the smelter's
                                                          "   (Continued on  next  page)

              :   Many   Rustonites
cite   smelter's  benefits
(Conttd from
 preceding paga)

emissions POM DO major prob-
 "I tMnk the greater majority
would have to agree with me that
there are no problems," he said.
 Depot? Clerk Norma Dottcette
said she's unaware of any adverse
effects of the smelter.
 "We have pretty lawn*, and
none of us have died from it (the
emissions) yet that I know."
 "A lot of people blame the
smelter for any problems that
they have." said Huston Clerk-
Treasarer Loretu Prettyman.
 Not all the people of Huston
have the same high opinion of the
smelter and its emissions,
 Larry and Jean Wingard stirred
the displeasure of some of the
town  hierarchy by filing suit
against the smelter for damage to
their ear and their organ* vegeta-
ble garden.
  The conple lost the trial of their
suit hot they now have pledged to
carry the fight against the smelter
pollution onward.
  "As long as there's a danger.'
she said, "we'll be there to tight
  Jean Wingard said many  of
 (hose 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 tans boy.
   "They're  getting paid down
 there to live and work in it" she
 said. "I'm not getting paid to
 breathe it"
                        Staff pilot, hr ««UC« LAMSOM

Healthful coexistence?
Seven-year-old Tonia Gibson is among dozens
age children Irving in the path of emissions fr
co smelter who witt be tested in a T,f coma-
Health Department study dunng »n« next wcwetw to
determine the levels of arsenic  in the.r bodies and its
effects on their health.



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

common  people,  not  rabble-
rousers." said Midiaei Bradley, a
Vasboa Island construction work*
er leading a group threatening to
take Asarco IDC to coot orer its
toxic emissions.
  •Tm not for tot loss  of jobs,"
Bradley was  cartful to explain.
•Tm a construction worker. I ap-
preciate industry and trade*."
  But Bradley said he and others
want the smelter to stop spewiof
arsenic and other **«•""•• *«
  Bradley is chairman of a group
tentatively named Island  Resi-
dents Against Toxic *•*»**** —
[RATE for short — that is prepar-
ing to battle on several fronts the
corporate bastion  symbolised by

toent Bay.
  The major concern of the group
is the toxic arsenic ***** <»•*<»«« inm
deposited on the island, apparent*
ly from the smelter.
  "Numerous people who staked
their life savings on a place and a
loroe are finding they can't enjoy
the land became of the emissions
of the Asarco plant" Bradley said.
  Many residents bought an cage
on  rural Vashon  Island so  they
could raise their own vegetables,
hop and turkeys, Bradley said.
And. be said, they purchased the
land long  before  anyone  knew
Asarco may be respmiahle for an
                                      ty  Superior Court case in which
                                      Rnston residents Larry and Jean
                                      Wlngard failed to convince a jury
                                      that smelter -—*•*«•'•• had poi-
                                      soned their garden.
                                       Tobin said the ease had "several
                                      technical defects" in its presenta-
                                       He **H the Vashon case would
                                      be  filed in King County instead,
                                      where  he believes a jury may be
                                      more sympathetic.
                                     i  The attorney also noted that the
                                      Wlngards moved into  Rnston,
       Michael Bradley

       island pollution problem.
         Bradley and other
                    cite 4% rccc&t T«J
                County Health Depan-

              wnich found  that soil on
               4 Maury islands hns the
                                   i they knew the smelter was
                              already operating.
                                'This (Vashon) is a rural com-
                              munity,  not  heavily populated.
                              where a lot of people rely heavily
                              on gardens for food." Tobin said.
                                Tootn also said preliminary re-
                              sults of a com puti
                              property values on the southern
                              part of Vashon may be adversely
                                       by the smelter's toxic
                                Some n
                  The highest level was
       found in Tacoma's North End.
         Vashon resident! also are
       awaiting results of tests to deter-
       mine the level of  arsenic  in the
       nrine of their *>*|ij->**in.
         Smelter Manager Larry  Liod-
       ouist denied the smelter —•*••«'«—
       were  harming  residents  of.
have  said some  prospective-
buyers will not look at property on
the southern part of the island be-
cause  of the «">-t^Tr trniiiKiit.
  Commenting on a new Envii'on-
mental Protection Agency propos-
al that  would  order Asarco to
ratal! new air-pollution  control
          Tobin said he is both
          and  disturbed by the
                                 "Until they have _
                               Tigirshlas they have
                               seems to me they

                                 "Inall the years weWhereand
                               have taken  set!
       IAM^^A • •« **^MMfciA T —-  ^B kA.
       •••««• IB fMOfne. i never nav
       values  high enough  to  worry
       about."  Lindqutt added.
         "The  studies don't support the
       contention  there  are harmful
       health effects." he said.
         Bill Tobin. an attorney living on
       Vashon. said the group must de-
       cide whether to file a flats artinn
       suit or individual civil suits
       against  the smelter.
         Because of the high smokestack
       and prevailing wind  directions,
       Tobin  explained,  "We are  the
       dumping ground for these pollu-
       tants without any benefits (such as
       jobs or Asarco tax payments)."
         The attorney said he is not dis-
       couraged by a recent Pierce Coun-
                                ToMa said he is happy the pub-
                              Ik  will have an opportunity to
                                       oo the proposal But he
                                   pollution equipment designed
                              to "unuft  arsenic  escaping into
                              the Rnston  area may mean more
                              tone metals may escape through

                                Bart  Klein,  another  attorney
                              living on Vashoo who is active in
                              IRATE, said he thinks Asarco is
                              simply "milking" the tiftiafAfp in
                              the Tacoma area as much as it
                              can whfle it prepares to shift its
                                        to other  parts of the
                                                    has been
                                                                Klein said the
                                                              allowed to violate air pollution
                                                              regulations for years.
                                                                "How many times," he asked.
                                                              "can you go past go without stop-


                                           INC leys iniouNc
                                           I •COBS ( IfoBn*
                                             Hay, 10 Aim 63
Sutherland calls Asarco 'good neighbor' on national TV

                        Tacoma mayor

                        wants to keep

                        smelter open

                         TAOOMA (AP) - Tbi mayor
                        of Taoama aays ha favor* kaap-
                        •— — ------ j~MAh_ IM tfe^
                        IBB dDHT UHUU IB Bl

                         ••Uatt m baa atate  to bt

                        Wedtanday OB ABCi

                         Sutteiaad sOd that wbJto tte

                                       Is doubt
                        Aaree bMtail $O mffltaa worth
                        J^ Ih^.^^fl^ ^^^^^ UM ^^^^^^^^
                        ai oooai ow B coppar

                        voten to trap part of tha an
                         Bat tha EPA hu pndktod tha
                        •	«- ^^n M^A •-
                        BOMB Will OBI i
                         Both Aaarco and EPA

                        aa|j|  «MiiM"tlltt¥  a^Mp^MP • A*

                                                                                                       l'n|« Ift  The Veihon-Mourr laland DIIACIICOMIII'.n  Aug. IB. I'JIIJ
 E.P.A.  proposal  isn't ample  margin  of safety
  Nalr  Im my nrarty 10 ymr* tf
«.••>! xporling. I few ilwfloiury
a«MoVd /!ru perion arlkln and
km* aifrmpfrif to leave out my own
rr.wwrf opMMmi frbwmrr. offer
Ifcr  4u|ml 10 bMrMMMiiial fro-
iKlkni 4jency UforliMaD fcr« con-
cerning arttnlc  tfandnrdi Jbr
jtMftCO. /ay Berftrr aitcd DM to
••'lit a pat* concerning mf f*r-
tnnat rtatlmu ondfttUnft:

  I  have lived on Vathon live
fr«n   I have  |lown  •  taigc
fnnkn lout yc«* and  I hecM.
moil ol my produce. calln| my
own   gatdcn    vegetable*
HiiiHi|houl the ye«. I have alto
tr|HMlcd on development* legal-
ding   ASARCO  lor   lh<
Ararkcombfr lot loui ytaii. In
talking  lo  libndcr*. cottectlM
d.ila on anil Hmplct horn llbnd
|.nilcni. and quetllonlng olflcUU
almul what II all meant.  I have
In-come  Incteailngly concctncd
alN»l   living   In  ASARCO'*
  Nevcilhek**. I went alnng hap-
|iil|> glowing  my garden  and
eating nif vegetable*. Then I
became pregnant My baby It doc
In Sc|ilember.
  Rerenl      Inloimallon
ili<«.-niinaled hy Taconia Pleice
County  Health  Department
warn*  agalnil  callng  kaly
vegdabki  horn lardem con-
taminated with cadmium. I alto
teamed that letinct. Infant*, and
chlldicn we the moat waccpllUc
populalloni I decided H might be
alright  lot me  lo ell Ihete
•cgdebkt. but  I thouUo'l ei-
DOM my unboto child lo Ibb t bk.
I didn't even plant lettuce. Swb*
chaid. of iptnecn.  h we* only
•tier I planted • Mg ciop  of

that I katacd Ihoac vtgclabka
loo ate iinned. I haven't eaten

  So ASARCO hat  teeUy come
home lo IOOM. allecllng my Hie In
• teal, tangible way. And Ukcly lo
do mote to at In the com M ol my
ictearcb I have betid oflldab led
me thai II might be dangeimit lot
o child lo play In the dltl on
VaiKon  became  el  elevated
Micnk kvela. I think 11)001 what
U meant for  e child lo live !•
yctrt bete, cipotcd lo the levdt
of ottenk aad cedmrnm and
ding atandatdt lor atatnk cmla-
•hmt at ASARCO «nt tdeaied. I
VffCtiiM owffc concct MQ* Pot UM
part  ala  month*, offkhb b>
dkaled (oil the  rccotd| Ihil  I
could ctpccl tlilngcnl mcaaatca
lo cntb   ASAROO   pottiitlon.

bccauie what  Bf A propntct b
nothing mote  than  what  bai
alf eadv been otdeted by the local
•It pollution conltel  agency. In
fact, what EPA propoxt It eiert-
If whet ASARCO wggealed be
naed ei • ataadaid lot Ml ettenk
In out hendi teal data Ibal Irfb a
Ibal out «cgcuMet«c dangrroM
to col. out cMUtcn-t Mbwrf
oticnk bvdt ere ckvalcd way
beyond  normal,   end  out
boncybcet ate dying becmite of
aiacnk pollulkn. BPA oflldab
leH M they lack the data to detet •
mine wbelhet Ibcic I* a teal pto-
                      14 teal  allualkm
                       have  of efl
                end ptcaenleft celt
  And  I  have become mote
cynical btcauic H aeemt IhaJ
once Ibete Iblngt ate ptopoard.
they lake on a We of IbcU own. U
b hard to change lock*, certainly
bard  to move • comptomlie
lowatd any  kind'  of  tadkal
change. The  BfA pfopoiat did
not atem lo addicea my Icata.
        TB» Meeting
  And  the  Augnat  10  .BPA
wotkihop  bete confltBMd BM
          and paade aae feel
  Wblk every offkbl I have talk
ed to m Ibe pad tool year* m-

Dca wnb emlnlont from Ibe num
Hack Iwllk Ike new koto) pto-
peacd by RPA. maw alack aiaealc
t minion* would Increate thu* h>
ctenalng our lUk of canccil. RPA
that Vetbon b affected mainly by
low  level* fiom  baki In the
cumulated and/at  continue to
contenuMic Ibe cnvfroaimenl b)
which  I  Uve. I have  become
aeiloualf concctned.
  When Ibe BPA ptopoul tcgat-
even more conceincd about what
b going on  bete. Ike pronaeal
doe* Italy aeem to have a Me of
Ha own  lit nlcbkwd appeal* to
be  a  mdhcmdkal computer
model which all agree baa very
queillonabb aiaumpltont bulH
  WhUe toil data ibowi thai
Vaihoo-Mawy libnd b Ibe etc-
ond hkjhol accne of ASARCO
         ne«t only lo Ibe
      I vktaUy of Rnalon. BPA
      I ckrimed Ikd Ikdt model
tkow*  our  pmnjblkm b  not
wllhm Ike 100.000 mod ci
                              And  then  RPA.  otfenilUy
                            benutt Ibe Oca* Alt Ad doeen'l
                            pctnill lakln* a bnk at Ike whole
                                                        tcfuatt to acknowledge thai out
                                                        pteaenl ttak b ckvalcd becaute
                                                        of peal poOulkm. Vim full can't
                                                        make me beBcve thai my tUfc and
                                                        my  cblkft tbk of getting  ikk
                                                        horn ASARCO-i pieaent pom*
                                                        lion bn'l gfcatct by the feel thai I
                                                        Bve m on envttonmcnl that b
                                                        already   contaminated   by.
                                                        ASARCO-* pad poHidlon.
                                                          H wa* afcw deptetaliig lo  Imd
                                                        thai BPA b bating Hi wbohded-
                                                        •on on Ihb coropulct njodel of
                                                              Ully  of  eaceat  cancer

                                                        •jMlfty of Bte doean't teem to be
                                                        BBtt M pfOlCClMBfl llW pMwHC'ft
                                                        leallb wben U doein'l mvoKe
                                                        Ibe  big demon  cancel. What
                                                        _•	»   aLI^  ••••••«*  fcblakMM
                                                        nooui   aam  oncoaca.  nmncy
                                                        mtturca, Bver falhnca. aalhmaT
                                                        Why ate  BTS Job* m Ta
                                                        than SOO Va
                                                        •tow garden* wkkh they Hvc on.
CO  gtow garden* which they •
bu>  tabc Rvcdoch fwlncb cd
                                                         lieenel fee tktugMet. flak to top-
                            again tUcatCB  latamlrn'  ouea-
                            Imna  by  aaymg "Supetfund h
                            atiodtttcd to deal wHk that pio
bkm." If* a lot of ptobkm lot a
progtam with a 1100.000 budget
to deal wnhl Why dean It up If H
  VVhlb I am Ibe daughter of two
bwycia and Ibe aider of Ihicc
and aavvy enough lo tcaUi* BPA
b reluctant lo gel taken lo couil
tut cicecdtng Hi (urlidldlon.  II
make* no logical tente why Ilie
agency doean'l Ibid tome way lo
lake a comptehenalve look al the
whok ASARCO probkm  The
beaetare natiowed lo Ibe link*!
focua. deaH with pfcccmeal. and
Ike   icauH  I*  nothing  really
  In  ptopmlng a dandatd lot
aiarnto etnlnloii al Ike Taconia
plant. I think BPA akould Im-
Mcdblel*  require ASARCO lo
me only low-attrnk grade etc |ai
b leejufaed d every ether copper
imettci In Ibe US|. the  tccon-
daty hood* akould be Installed by
I9M.  and BPA ifaould  move
quickly to prove Ikd H b pro
vkltng an ampk margin of nitty
lot out health. II Icannnl cat my
garden •egdabk*. RPA h not
ptovkftng  me wHb  an  ample
  Otbcrwbe. I can only conclude
Ihd Vaiboj laknd b not a veiy
       -MaryOI. Sliarkclfoid

                     THE SEATTLE TIMES
                     Friday, 19 aug a3
 '1 should be dead, if
 you listen to them...'
 Longtime Asarco employees contend
 health risks are exaggerated by EPA
^^•OT fW*f+ M M MA a
•^K* MBCB M •. W« ilVBM MB
«*« •« *
* 10 Tht S««a> Tlnm  Pndav. August 19. 1983
Workers say
health risks

You  become immune to arsenic
 To The Editor According to re-  because of a regulation saying we
cent  headlines in  the  Tacoma
News Tribune, I should have died
20 years ago.  I retired from the
Tacoma Smelter four years ago.
after working  there for 30 yean.
The first 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  UD  me; and I
don't believe I will die from can*
cer. The human body builds up •
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  * . C .
main reason I retired early was  ^
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
      people are allergic to their
     or husband.  Heart disease
       SI percent of the U.S.
deaths. Cancer causes 21 percent
of the deaths in the U.S. Accidents
      S percent  of  the  dfaths.
                              Other causes account for the final
                              23 percent
                                So what part of the 21 percent
                              cancer  deaths  is  the  Tacoma
                              Smelter responsible  for?

                                         JOHN C. LARSEN,
                                            **•! So. Warner

   Smelter   closure   opposed
 Health  hazards have not been proven, state scientist says
  Health hazards resulting from
 Tacoma smelter emissions have
.never been proven, says • state
 scientist who has studied UM ef-
 fects of the smelter's anenlc cm*
  Therefor* the smelter  should
 not be shut  down  DOT  should
 stricter clean-air standards i
 sarlly be Imposed, said Dr. Samu-
 el Mllham. an epidemiologist with
 the state Department 6? Social
 and Health Services.
  "Unless you  can demonstrate
 you're causing a public health
 problem. I think It would be Irre-
 sponsible to be closing the i'
 Mllham said. "And we  "
 haven't been able to demonstrate
  Mllham addressed a study ses-
 sion of the  Tacoma City Council
 yesterday at the Invitation of
 Mayor Doug Sutherland. The city
 Is to host a daylong fonim on. the
 Environmental  Protection  Agen-
 cy's proposed tougher arsenic em-
 issions standards on Oct. I. Aaarco
 officials and • variety of environ-
 mental and public health organ-
*Dr. Samuel Mllham
Isatlons  are being Invited  to

  "My recommendation to that we
should make the air as clean as
possible within the limits of eilst-
Ing technology." Mllham said.

  Studies have Indicated that the
eiposure of  Asarco workers  to
toilc arsenic Is JO to IM times
greater than that among the gen-
eral  population,  and their Funs;
cancer rate Is X to J times that of
the general population, he said.
But studies have not established
any  arsenic  threshold. Mllham
said - that Is. the degree of eipo-
sure  at which arsenic emissions
may actually, cause cancer.

  The EPA  has estimated that
four cancer deaths a year can be
attributed to the smelter and the
proposed stricter standards would
reduce that to one. But  Mllham
said  the  RPA's figures  "don't
match reality."
  "The  critical question  Is
whether lone-term tow-level eipo-
sure (to arsenic emissions) to dan
gerous." Milham said. "There's no
doubt that workers demonstrate a
higher cancer rate, but their eipo-
sure to at high levels also "
  Mllham said be conducted ex-
tensive studies In It71 of pupils at
Huston Elementary School across
the street from the smelter and of
pupils at Fen Hill Elementary
several  miles away (the control
group). The studies showed "the
only thing different about those
(Huston) kids to that they don't get
bee stings, 'cause arsenic kills the
.bees.-he said.
  "They haven't  had a bee sting
there In II years"
  Although children In Huston
showed higher levels of arsenic In
their urine, fingernails and hair
than the other children, they did
         to suffer any  health
problems as  a result.  Mllham
noted. Levels of absenteeism and
academic achievement were quite
similar at both schools,  he said.
Fern Hill was chosen as a control
group because Its students' social
and economic backgrounds were
similar to those of Huston pupils
  Mllham said In It7l  he
searched out  men who  attended
Huston Elementary In If II. when
the smelter began processing ar-
senic rich copper. He traced 10
percent of them and found that
only 1 In SO had died of hug can-
cer, although at least halt had
worked at the smelter at one time
or soother and many of  them
lived In the Huston area all their
  While there to no doubt that ar-
senic can be dangerous, how much
arsenic  eiposure to harmful has
not been demonstrated, he said.
                        TIC  fCklS TRIBUNE
                        Tacoma, klash.
                        UednuBdny,  1<«  Sep 03
                                     Page B-l

                           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 Do's and Don'ts of Listenine. from I Hear You, by Eastwood     9
           Arwater, 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, NJ., Division of Science and
           Research, NJ. Department of Environmental Protection, 1987).

      •     Ten Wavs 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, N J., 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 McCallum.

      •     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
          Environmental Protection Agencv  '988
          Washington DC 20460      QPA-87-020
&EPA    Seven Cardinal
          Rules of Risk

              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 all 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
spokespeople 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.  Identity 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, voiuntanness, 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 nsk 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 almost
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
                                                        all inter-organizational and
                                                        intra-organizationai 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 monvated.
they are quite capable of
understanding complex nsk
information, even if they may not
agree with you.
Tliis pamphlet was dratted by Vincent T
Covello and Frederick W. Allen, with tlie
assistance and review ot numerous
colleagues in and out at government.
Covello is Director vt the Center tor Ri>k
Communication at Columbia University
and is currently  President ot'thc Sivietv
tor Risk Analusis iSRA). The vieii'S
expressed here do not neccssarilv
represent the vieii'S ot Columbia
University  or the SRA. Allen is Associate
Director ot  the Office ot Policy Analysis
at the Environmental Protection A^enn
(EPA). The EPA has published this
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.
TJie authors invite vour 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
      O highly technical analyses that are often unintelligible to lay persons;
      Q sheer amount of complexity of the analysis.
Source problems Include:
      Q 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.
Adapud from Kit CmmmiiiifHim A ««wo» eftl* Uunaun. a repon prepared for ibe Eavnonmeaal Proiecuoo Agency. Augun 1987 h>
Vineew T. CoveUo. Paul Slavic, and Detlrf Van WiaurfddL

Channel problems Include:
       a  selective and biased media reporting that emphasizes drama, wrongdoing.
          disagreements, and conflict;
       a  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;
       O  lack of interest in risk problems and technical complexities;
       Q  overconfidence in one's ability to avoid  harm;
       O  strong beliefs and opinions that are resistant to change;
       Q  exaggerated expectations about the effectiveness of regulatory actions;
       Q  desire  and demands for scientific certainty;
       Q  a reluctance to make trade-offs between  risks, costs, and benefits;
       Q  difficulties in understanding' probabilistic information related to unfamiliar
                         Kevitw tfdit Liutaurt. » report prepocd for the Eovoooanul fmeaioa Agency. August I OH" h>
Viaceat T. CovcDo. Pud Slavic, tad Detlof Vaa Wiawfeldi.

Some  Dos and Don'ts of Listening
by Eastwood Atwater
In a crisis situation, you win be faced 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 mlstery
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 quickly?
     Do you interrupt too often? A better awareness of your listening habits is the first
     stage in changing them.

2.   Sham responsibility for ttw communication.
     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.

3.   Be) physic ully ottentive.
     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.

4.   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.
•Sane Dm and Don'u of Limning' bam / Hair Yat, capynghi 1986 by Euiwood Atwucr. Prenuce Hill. Englewood Cliffs NJ P
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
      pan tends to make a speaker feel defensive, insecure, and more guarded in

8.    Express empothetic 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 the feelings stimulated in you by another's message, and can
      express those feelings, this clears the air and helps you to listen better.

10.   "Close the- 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.
    DM tad Doo'tt of Luteajag' from / Hatr You. copynghi 1986 by Eamraod Aiwaicr. Prentice Hall. Englewood Gift. 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 icmain 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.

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. tr> to
      follow with a retrieval—helping the speaker to re-establish the train of thought.

4.    Don't pass judgment too quickly.
      Judgmental remarks invariably put others on  the defensive, serving as barriers tn
      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 Ooi ud Doa'u of Lisicuog" from / Hear You. copyright 1986 by Eanvood Alwiier. Preouce Hall. Englewood CliHi \i

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 on the defensive.

7.    Don't ever teflo speaker 1 know exactly how you feel/
      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 mat 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 to, hear.

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 On and Doa'tt of Liiteniog' Iran / Hear Yen. copyright 1986 by Eastwood Atwaier. Premies Hall. Englewood CUffi. NJ. I"»M

                            Submitted to:

               New Jersey Department of Environmental Protection
                      Division of Science and Research
                           Contract «C29444
                           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
                              TABLE OF CONTENTS
              How Communities Sec Risk
                    Factors In Community Outrage
                    Yes. But
        IL    Earning Trust and Credibility
                    Yes. But.
                    Ten Ways to Lose Trust and Credibility
        ITT    TV^Mlxff Wton fa P»1»ag*
                    Yes. But
                   • Ten Reasons to Release Information Early
        TV.    Interacting with the Community
                    Ladder of Citizen Participation
                    Yes. But
        V.    Explaining Risk
                    Yes. But
        VI.    Ten Myths of Risk Communication
•taproviag Dulofue with Coaaaaiuet.' written by Ooo Oca. BJUe Jo Haoee. tad Paa Sudmu of the Eavmmmeaul Commuoicjiioa
RouNk Pnpim 

             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.

             Rtekrmrmnntcatlnn can hrip agencies to:

       •    • 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.
                  nintcsttng about euvtiuiuiieiitdl 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
                         u*^ aru\ R»yyi»)l (iitvf^^hy ftpH| P^MTg'H PSmrt PH^UIII)  (few
       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 50 academic experts, industry represen-
       tatives* citizen IMMJ^**^ md agency 5*gff throughout. **** countxy.  *rh*«» ytgg^ti^n^.
       have undergone a icview 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 for 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 is an abbreviated version of a longer manual, ts useful to
	those who wish a quick overview of how the public sees risk and how to improve inter-
"Inpraviag Dialogue with Communities.* wrreea by Ccrao Chen. Billie Jo Haace. ud Peter Smrtmin of (he Envammeaul Commuaiciuon
Refund Program a Cook College. Rotgen Uoivenhy. 1987.

actions with the public.  As such, this guide may help orient new staff or those unfa-
mlllar 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 enure 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
•uflflcstloos hfrr strike you aa> a> bit toft "cut ftfi dried*" also consider **«***«««^*"ff th«»
longer manual for more substantiation. Although the guide you are reading contains
nearly all the 'guidelines' in the longer version and sections entitled "Yes. But...." to
deal wtth the most likely concerns, we have omitted a variety of features:  (a) in-depth
             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. fThe 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 Rtsic Communication to Government! Suggestions for Agency Management." also
available from the Division of Science and Research.

       Many of the suggestions to 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 win
              with Commmiuu.' wnnen by Caroo Own. Bfllic Jo Haocc. ud fact Sandman at the Envoonmcaul Canuiwaiu>H.a
 Roendi Prafnm ti Cook College. Riagcn Univeniiy. 1987.

                    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 seal belt are risks that people choose, not an environmental rtsk
      that chooses tlicui). people become even "5*^

            In order to break this cycle, agencies might begin by recognizing that communi-
      ties are quite capable of understanding the scientific aspects of risk assessment.  The
      public" includes doctors, chemists, and teachers, as weO as persons with less scientific
      background, who understand many of the technical Intricacies of risk.  In fact, while
      government personnel may change over the course of an environmental problem, resi-
      dents of affected communities often remember studies, reports, and agency actions with
      an impressive  amount of recall.  Too often government assumes that because communi-
      ties dont agree with an agency action, tr.ey dont understand 1L

            Because outbursts of citizen anger make agencies understandably uncomfort-
      able, they also tend to forget that public outrage can be extremely positive.  In fact.
      most environmental agencies and a significant number of the laws they enforce are the
      results of citizen campaigns, fueled by anger over environmental degradation. Funding
      for these laws, and consequently for agency staff, also depends in some cases on tough
      legislative battles fought by citizens. In addition, most agencies can admit to a number
      of environmental problems that wouldn't have been uncovered were it not for commu-
      nity action.

            On the other hand, agencies particularly resent anger directed at them rather
      than at the environmental problem. Unfortunately, agencies tend to act (often unwit-
      tingly) in ways that provoke such anger.


            Admittedly, public fears are often not well-correlated with agency assessments
     While agencies focus on data gathered from hazard evaluations, monitoring, and risk
     assessments, the public takes into account many other factors besides  scientific data,
     Collectively, it  is helpful to think of these non-technical factors as the 'outrage' dimen-
     sion of risk, as opposed, to the "hazard" dimension more fazznliflr'to agency profession-
     als.  Because the public pays more attention to outrage than the experts do. public nsk
     assessments are likely to be very different from agency risk assessments. Ignoring the
'Improving Dialogue with Commnnhiei.* written by Caron Qieu. Billie Jo H«nce. ind Peter Sandman of the Environmental Cmrunum. *,••«
Reiurcb Program at Cook College. Rutgers University. 1987.
                                        17  .

 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 mare readily then those that are imposed.  When
 people dont have choices, they become angry.  Similarly, when communities feel co-
 erced into accepting risks, they tend to fed 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.     Risks under individual control are accepted more readily than those under govern-
 ment eontroL 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
 wttbj the data •our driving lecuitl versus the driving leuud 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.

 c     Risks that seem fair ore 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 win find the risk unfair— and thus more serious. This factor
 explains.- to part, why communities that depend on a particular Industry for Jobs some-
 times see pollution from that industry as less risky.
tffl      aDfol^f* 4M AMMBMVf^HSi tflMHfr 4MM^k^BM Aw^^Bfe fBI^^M^toi^i^HrtAM* ••M^^>^H^^^B> J^S« •^BMM^VW^M^MMIb* B^tflM^Mf^^vf
tfum fri/brmoUonJrom ururusouorthy sources. If a mechanic with whom you have quar-
relled to the past suggests he cant find a problem with a car that seems faulty to you.
you will 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
far 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.      Risks that seem ethtcoBu objectionable wtU seem more risky tfum those that don't.
To many people. poUution is morally wrong. As former EPA Assistant Administrator
Mitten Russell put. it. speaking to some people about an acceptable level of pollution is
lite talking about an acceptable number of child molesters.
'Baruch-Flschhofc Pl^ Slavic, sad SanhUchteuteln conducted much of the jmond-btaktng
 'Improvug DiilofM wnh Comaaaitie*.* wiinca by C«ra Chen Billie Jo Hioce. and Pewr Sudan cf te Eaviroameaul Coaumioiuiioo
 Research hopim it Cook College. Roi(en Uaivenhy. 1987.

      /.      Natural risks seem more acceptable than artificial risks. 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 thanfamtltar 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 an associated v^other, memorable events are
      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 of these factors, the greater the likelihood
      of public concern about the risk, regardless of the sctentfflc 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  variable*. 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
      soxnetixnes been snouted down when trying! to present data because cuuuiiunlUes 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  dloxln.  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 rOTTf T*H5 Were P^T** htlpffi tO M**HyS* *r\i\ ]\\f yto«M»  anrt
'Improving Dialogue with Communities.' wraea by Oreo Qua. Bilbe Jo Hance. tod Peter Sandman of *e Environmental Conunuaieaii.>n
Research Program at Cook College. Ringen 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 need to take into account other factors as well.

•      Our Job to to protect public health.  That means relying on data, not deal-
ing with outrage/actor*.

      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 will have less time for serious risks.  In short, one way
         • agencies wffl hate to 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 in 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 kad to better technical solutions.

•      If It wen not far 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 oPW**?** themselves, who
uuwitUugly 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 tzylng to understand citizen concerns.
 •tapro»iog Dialogue wHb Commuaiuei.- •rinca by Cra dien. Bflbe Jo Huce. iad Pcwr Sudmu of the EavaoamaMl Comnmaic*.,oo
 Raench Pretnra u Cook College, tagen Uaivenity. 1987.


            Agencies achieve trust, in 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 fall to "be credible," you will virtually guarantee community opposition,
     in the form of both disagreement with the science and leseiitiiient of the agency.

                   Bruce Bentley. citizen participation specialist at the New York State
            Department of Environmental Conservation, points out that • 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 (allure to ask people about disposal of the PCBs.   Bentley says. "We
            (ailed 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 the ccltexU and certainly, therefore, not willing to buy Into the Hie.'

                   Conversely, trust can be built by dealing with the public forthrlghtly.
            When a flre contaminated a Blnghamton office 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
            unafllllated 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
            people1 to tff Hie* ktiKT of Interchange that went on beliHes, these *T*^* when it
            CTHTC* to* making* dtffl cult decisions."

            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: (cl 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.

     3.     Pay attention to process. In many cases citizen opposition focuses not only on
     agency action (or inaction), but also on the manner to which the agency proceeded
     toward that action. Try. whenever possible, to involve affected communities in agency
           Explain agency procedures.  Communities need to understand government's
            nmrlrinaa aitit agmflm m. HB**1 tO SQOW *Ka» «hpy «TH^ *" mnm* logical
    Indtc&te how public input fits into the process.
•Improving Dialogue whb Commuaiuei.- wrmeo by Oreo Caen. Billie Jo Hince. ud Peter Sudmio of the Eaviroameaul Comnniaiciii.-
Reteweb Plognn at Cook College. Ruigen University. 1987.

   •People read the agencies and their actions more carejutty than they read the details of
   the studies.... That's what we have generalized skill at'  Banich Flschhoff. leading
   researcher on risk perception, Carnegie-Mellon University.
 4.     Be forthcoming with Information and involve the public from the outset. If
 you fall 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.)

 8.     Font on building trust as wen as generating good scientific data. As
 explained in Chapter I, people's rt^M in*Ufm»nt^ arc ^i^m^i haa^fl solely on scientific
 inforBMtion. but rather on a combination of to
 other variables, and their feelings about the agency.

 a.     Follow up. When your promises fan through the cracks, you might not notice.
 but those to whom you made the promises usually do. Make every effort to get back to
 people and check to see if your promises are becoming reality.  In particular, consider
 making sure that notes are *pfc»q at public meetings regarding rfrrr"" impression of agency ineptness.  Responses to various
acknowledged and explained.
 -Invnmat Oulofoe with Coanmiiie*.- wtraa> by One OMH. Bab Jo Hue*, tod Pew Sudan 
      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 groups 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.
     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 foxthnghtness or more extensive community involvement.

     15.    Avoid "closed' meetings. While casual meetings- the routine turning of gov-
     ernment wheels- are rarely suspect, private meetings- those dosed 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.

     18.    If yon are dealing with a situation in 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-
            tion — •

     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 peisoiul level, when appiuuilate (see 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 is logical. The reason they don't
       trust a»ts thatlaedtJnttnuotof them frrthedectstans.* Brace Bentley.Ctt&enPanici-
      patlon Specialist. New York Department of Environmental Conservation.	
•Improviag Dialogue with Conmuaiiiei.' wrmeo by Ccroa Qieii. Billu Jo Htaee. ud Peter Sandnua of the Enviranmeoul Cownuaiuiioa
Research Program u Cook College. Ruigen University. 1987.

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

       True. However, the fact that you can't earn the trust of aO the people all the
tune does not Imply that you should forgo the effort. Check to make sure that—despite
a basic 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
fan trust »="**' other's integrity arul •**!! HIVUM i»» on ft«*i«iain»iifflj matters.
 .'•.*'"'>  •"•'•  • • •  < '  '    •  "•'• •:"•'•'.'. "•'•   •   ;  " %'--"r .''..--
 : :     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.

  1, -..  . Don't Involve people fai decisions that directly effect their lives. Then
        a<^ defensive when your T"^10**^ are challenged.
  2.     Hold onto fn/ormatlon until people ore screaming/or It. While they are
        waiting, dont tell them when they will get it. Just say. These things take
        time." or 'It's going through quality assurance."

  9.     Ignore peoples'/eellng*.  Better yet. say they are Irrelevant and irrational.
        It helps to add that you cant understand why they are overreacting to such
       . a small risk,  •'..  .-.","-                        •       .. >

  4.  - •  Doift 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.

  8.   '  {f you make a mistake, deny It. Never admit you were wrong.

  6. ••;'•  {f you don't know the answers, /oke ft. Never say 1 dont know."

  7.' .. ; Doirt speak plate Enaflsh. 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."        ... .:..,,..          ..
  \. f  .      '     •    m f            . f           •  •[     "!*•". f" •
 . 8.  ":.•'.. Present yourself like a bureaucrat. Wear a three-piece suit to a town
  .- / : 'meeting at the Jocal grange, and sit up on stage with seven of your col-
  '••\r.. leagues who are dressed similarly.                .  ... ......
                           .   .          •     ,   • f «v. •  ' '          %
 "** .." '%" vC. ' *     .... A    . . •.      *•"•,'         '               ' •
 9.  '"  belay talkutff to other agencies Involved- or other people Involved wlthm
   .  *'' • your agency— so the message the public gets can be as confusing as pos-
   ;•/•  alble.    ...
 * 14ft n ""' • Vw^^k^ai^Bi ^aiaf ••^^••Mi ^MB^^a^Bd^evtf^k la*JBMV 'tfMHinolftff9 ejaBf^v^wWaw* tfva> eja^BMBBwC^ * ItotfVtf^Btf 0M

 ' ••; '^- and, has begged not to. send him or her out anyway.  It's good experience.
•In^nviat Oitlofaa with Comnmitia.* wnoea by Caoo Chen. Bfllie lo Haaoe. ud Peicr Sudmu of the EovaoBmeaul
Ratwck PrapuD a Cook Cdkfe. Rouen Uaivenity. 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 view as responsible caution. cuiimmiUttcs are 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.

                    For exafflDle* Susan Santos* formerly with the Supezfund> pcofiram> in
             EPA Region I and currently manager of the Risk Assessment Croup at E.C.
             Jordan Company, was once In a position where the release of test results was
             delayed for three months while the agency analyzed an additional round of
             samples. Interpreted (he 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. IT not Impossible.

                    On thy other *»•«««*. Bruce Bentley. citizen participation •p**-tj|i** with
             me Hew York DevaitiiieiU of EnoliuiuiieiHal CmismaBuii. tefls-ef a 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 mail. Informing residents of times
             for 'availability sessions' with state and county representatives to answer ques-
             tions. People were alerted to each step of the process before It happened, and as
             a result discussion with the community centered on the risk Itself, not on the
             way people were? weatco.
             The following suggestions provide guidance about deciding when to communi-
      cate and steps to take if you decide to delay release.

      1.     If people an at risk, do not wait to communicate—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.

      3.     If the agency la Investigating a potential risk, that people .aren't aware oC

      When an agency announces findings from an investigation people have not been aware

"Improving Dialogue with Communities." wraea by Circa Chen. Bilbe Jo Huce. and Peter Sudmu of the Eavtronmeoul Commuiucaiion
Re*eirch Program u Cook College. Rmgen University. 1987.

 of. the agency is forced to defend its 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 seems 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 onct the accurate portrayal of information.

 4.     If it Is likely that the media will "fill la" with information concerning an
 on-going story while they are waiting for yon 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 tone defending your views or your credibility.

 5.     If you really don't trust your data, talk to the public about your procedures
 bat don't release the data. Obviously, hold onto data for which your preliminary
 review shows serious qualtty control ormethodological flaws. However, be up-front and
 t»n «»«tf»»Tiq what ha« happened and when they will be able to. gft some results.

 6.     If the preliminary results do show a problem—and yon are fairly confident
 of the results—release them and explain  the tentatlveness of the data. If you are
 (airly 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-
 aider, instead, giving people risk management options, not decisions, when you release
 the data. Then work with them to develop risk management decisions. (See Chapter IV.)

v.     If yov feel the Information win not make sense unless released with  other
 relevant Information—and you don't have all the  Information yet—wait to release
        you're designing en Investigation or a regulatory strategy, the communication
        t*oftlnjtt*t na mttAtt fly ttf^f yff  Ewmmeaul Cammuaicai..
  Rcttucb Propm « Cook Caifefe. Rugai Uaivenity. 1987.

        "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 going to be problems. But at least we can tell
        them what we're doing.'  Gary Sondcrmeyer. 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 a* aoon aa you can.  If piecemeal release of information would seriously disrupt
      the agency's program or the public's ""riiretanHing th«m i»nn
•      By releasing Information early, we may 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 of legal liability (five release In/brmarion early.

       Hie number of cases In which liabfifty Is a primary concern—rather than a
conaenlentrationale Isqnnttnnabte. "Can we do this?" wiD probably ettctt a different
response from a lawyer than "We want to do this, so can you help us deal with any legal
concerns?' 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
  ••:.•>..     ..       ....               v              „ . ,••
  , ' ; *  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 "**^ 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 rdease of InformaUon seta the pace for resohatlon of the problem.

   .3. ; If you watt, the story may leak anyway,  xtrheff ft cloca> you are-apt to lose
   4.  -. You can better control the accuracy of information If you are the first to
   ' •"'   present It.    - ••  ?..'•..•.'••/:•./•        •  ->•    %  -., ••  •,:  '"• •  •

    5.  There is more likely to be time for meaningful public involvement in decision-
   , .   making If the information is released promptly.      -    .

   6.v  Prompt release of infbnnatfoa about one situation may prevent stmuar situ-
        ations elsewhere.

   .7.  : Less work is required to release information early than to respond to inquir-
   -L;-; tea, attadcs. etc. that might reside                             ; .;
   . '•>,*." '\>'^<'.L.'.^r,^;-
              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 is 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 Taeoma. Washington EPA was confronted with a difficult policy
              question: How should the agency regulate an arsenic-emitting smelter that
              piuvkied • substantial economic base tar the canmnntty? The problem Involved
              (as environmental health problems often do) Issues of equity, economics, and
              community value* m 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 Anal decision rested with the agency, EPA demonstrated by word and by
              action genuine Interest In the community's concerns and values.  For example.
              EPA stafT 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. InformaUonal presentations were followed by quesUon-and-
              ajiswer sessions in stnarl groups. ladlltated by people from outside the* agency.

              In lacoma Is an example of an  agency respecting community values and attempt-
              Ing to Involve people outside the agency meaningfully In the decision-making

                     Lola 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 funds 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.

       1.     Recognize the importance of community Input.  Citizen involvement ts
       important because: (a) People are entitled to make decisions about issues that directly
       affect ****** lives; (b) Input from the community ran help the agency make°better deci-
       sions.' (c) bivulvenent in the process leads to giedtei uiulei.iMiii,Hiigof-~apd' niuie
       appropriate reaction to-a particular risk: (d) Those who are affected by a problem bring

•Improving Dulogne with Conunumuu." wmun by (Uroa Chest. Bilbe Jo Hioce. ud Peur Sudmu of the Eavironnmul Cammuaicun-n
Reseuch Propun u Cook College. Rngea L'oiveniiy. 1987.

  The communto/ (s (he expert about possible routes of exposure and what they are most
  concerned about" Raymond Neutra. Chief. Epldemlologlcal Studies and Surveillance
  Section. California Department of Health Services.
 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.

 2*     To the extent pfmfhlft. Involve the community IB ***-» ^^uu«i«*n-»n«>fcitt^
 process.  Agencies typically spend considerable eflortdevektping a risk management
 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 controversy, 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 foDowing page, citizen
 involvement takes a variety of forms from fairly minimal participation CGovernment
 Powell to 1'TMiT'tr taking the lead ("Citizen Power"). Consider placing Agency intense*
 ttonswtth the comnrantty at m higher rung' 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 1L

 o      Involve the community at the earliest stage possible. Meaningful input is
 easier before agency staff fed  committed to a course of action. Communities are also
 more likely to be responsive to agency ideas, when, they an involved early.

 «      Clarify the public's role from the outset.  In other words, clearly define your
 position on the Citizen Participation Ladder. For example, dont promise the public
 input and then essentially ask for ratification of agency decisions.

 •      Acknowledge situations when the agency can give the community only
 limw-Mi power In the decision-making. Present legal or other constraints (resources.
     , staffing, regulatory limitations, etc.) from **** outset, but avoid i*«**'ff tii«mi as false
     ses.  Consider cumlmmity suggestions for ways to deal with these constraints.

       Find oat from communities what type of involvement they prefer. Different
      unities win want different types of interaction and should be consulted about
these preferences.

3.     Identify and respond to the needs of different audiences. Although the term
the public" is used throughout this guide, in fact there are many publics, each affected .
differently by an issue. Depending on the issue, the agency may need to communicate
with industry representatives, environmental groups, civic organizations, sporting or
recreational associations, local government agencies, local elected officials, local bust-
HM^^MIBi VmW^MtV tf^HMMW Wttl^M ttf* YlVAflA iflfffVW^£efc C^MMftWl Yt^ tel04lMA4tfi ttVMt flVMlfWV
with about {/u£r concerns.

•In-mviag Dialogue with Commaahie-.* wrmeo by Ctrao Chen. Babe le Hence, end Peter Sudani of the Eroroaneaul CamimiaicMion
Re-em* Procnm « Cook Galkfe. Ratten Uuvenhy. 1987.

                          THE STATE UNIVERSITY Of NEW JERSEY
                      Environmental Communication Research Program
                      A program of the Agricultural Experiment Station
         Cook Coflege • 122 Ryden Lane • New Brunswick • New Jersey 08903 • 201/932-8795
        Citizen Power
      Government Power
   Citizens act without
  communicating with
• volunteer fire department;
• citizen investigation;
• citizen development and
 implementation of programs
                       • funding of citizen groups to
                        hire technical consultants
Citizens and government   and/or implement projects;
 solve problems together   " dtizen oversight and
                       • meetings called jointly by
                        government and citizen groups
                           Government asks citizens  • citizen advisory committees;
                           for meaningful input and  ' informal meetings;
                           Government asks citizens
                             for limited input and
                           would prefer not to listen
                       • most public hearings;
                       • most requests for responses to
                        formal proposals;
                       * pro-for uia meetings and
                        advisory committees
                              Government talks;
                                citizens listen
                       • some public meetings;
                       • press releases and other
                        informational strategies:
                        newsletleiSf brochures* etc
Government acts without
  ommunic..!,.,**    '.yySSSSSit^m
•Improving Dialogue wi* Comimiaitiei.* wnaen by Cjroa Qieu. Billic Jo Haaee. and Peter Sandman of the Environmental Communication
Research Program ai Cook College. Rutgers University. 1987.
                                                  Risk Communication: Resources • 21

  'People have to identify with people as human beings.... Rapport Is the key.'  Vincent
  Covello, Director. Risk Assessment Program. National Science Foundation
 •      Try to identify the various interests in a situation at the beginning and
 meet with them informally. This 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 rale 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).

 •      Deal 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 publie hearings. In particular.
 hold smaller, more informal meetings. 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 you eannot 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 wait a long time to

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

 •      Bo clear about the goals for the meeting. If you 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.

 •      la 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 Commuuiiei." written by Caton Chen. Billie Jo Hance. aod Peter Sandman of (he Environmental Conununicaiioo
 Research Program at Cook College. Rutgers University. 1987.
 22 • Risk Communication: Resources


     B.     Recognize that people's vmluei and feelings are a legitimate aspect of envi-
     ronmental health issues, and that such concerns may convey valuable informa-
     tion. Feelings are not only an Inevitable part of environmental health issues, they often
     contain valuable Information about: (a) what is important to people; fb) 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
     •      Listen to people when they expres* their values 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: "I 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
     providing information.

     •      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.

     •      Recognize 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.
     *      0V BWBF£ O* yOBF OWB WnZCV 4U1Q flcCUB^V ABOUT 8B BW0 flBQ CDC CTTCCt
     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 poli-
     cies 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 dear-cut and people need some
     context for their own decisions.

     •      When you speak at a public meeting, ten people who yon are. what your
     background is. and why you are there.  Give people a sense of why you are qualified
     to discuss a topic and what you can and cant do for them.
       "Ybu 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 ts impersonal ... tt can be much more
 •      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 wiD be treated accordingly.

 •      When speaking personally, pnt 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.
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

?•     Use community relations' staff to amplify' community concerns' wftUB 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
adeouately. People who cannot foot with communication) tasks should> TVtf' bf reoulred
•      Technically qualified people should have a major role in communicating
with the public about risk. Communities usually want to talk to people who are
directly involved in problem-solving.

•      Hake sure that representatives are appropriate to the situation. Send
people who have the expertise and authority to respond to people's concerns.

•      The agency icuieseulaUfe should be consistent thioughout the life of the
project or situation, if possible. Trust takes time to build.

•      Zn tome situations a non-agency communicator may be more useful than
someone from inside the agency. Consider using academic CTPfrts. Twal community
people, and representatives of civic organizations (such as the League of Women Voters)
to present information, This needs to be done with care so that such groups are- not
perceived as agency
 •Inpraviaf Dialogue with Commnnitki.' wrinea by Cam Chut. Billie Jo Haace, tod Peter Sudmaa of the Environmental Commuaic*..*
 Resmdi Profraa at Cook Collefe. Rufen Uoivenhy. 1987.

       YES, BUT...
       •     As on agency, we 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
       •tress on the part of the community, but ultimately will also undermine the agency's
       ability to luijjleuieiil risk management decisions.

       •     Communities worry about the -wrong" risks. Involving them in decision-
       maldno 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'
       values) are TVT more legitimate than «^>***"m**m^^*i  FintH^rmfm* <« 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 hone the time or resources to do the type of outreach recom-
       mended in this ftiide.

             Some changes suggested in this guide do not take more time and money—
               shift fa attitude.
      feelings than to argue with them.  Although involving the public In decision-making can
      be labor-intensive, to some cases 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 Communities." wnnea by Ciroa Chui. Billie Jo Hun. tad Peicr Sudnua of ilic Enviroomeoul Commuajciii-n
Round) Program u Cook College. Rmgm Univeniiy. I9S7.

                               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.)
             star? of attempting to explain the additional risk of a resource recovery facility to
             a 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 members of the audience Jeered. Although scientists felt the Increased risk
             was negligible, the agency's process spoke louder than the risk numbers. It was
             unlikely that any magic combination of words explaining the risk would have
             reduced the hostility caused. In part, by the community's lack of power.

                    On the other hand. Susan Santos of the B.C. Jordan Company, who
             formerly worked for EPA Region I. spent considerable effort dealing with commu-
             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 did. 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 their fears, 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 la the long run.

             Although "explaining* skins are also relevant, the moral of these stories  is that
      the agency's attitude toward and Interaction with the public are key variables in ex-
      plaining risk.

      1.     Consider the ootsage factors when explaining risk,  hi order to avoid upset-
      tmg 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 aa ranch emphasis aa the numbers.
      Give aa 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 Chapter m.)
*In*rovia| Dulefoe wish Commaaitie*.* wrioca by Cvoo Cheu. BUlic lo Hiace. ud Pew Sudaun of the Eovmnieaul Cannniaiciuon
Rnaicfa Piagnn u Cook Calkf* Ruigcn University. 1987.

 •      Be sensitive to related Issues that 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 dtfrerences between the risk information scientists and regulators ****"** 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 watefH and incorporate
answers in presentations nr><1 tnfnrmatimiai materials. Some practitioners suggest
speaking personally and giving 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 from a risk assessment, explain the
risk assessment process before yon 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  In perspective. Avoid dichotomising risk. Agencies should avoid
fueling communities' tendency to see risks as "safe" or "dangerous." Instead of present-
Ing standards as a cutoff 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-
  "Heolth matters raise very strong fears, concerns, and emotions among people. To
  treat it as a technical analysts and not to recognize the extent to which people feel
  strongly, not to acknowledge their concerns and fears and attempt to deal with them
 •«» aJatat mtstafce_~ Vincent CoveHo. Director of Risk Assessment. National Science
  Foundation    ....•»..                   .  .         •               j
 'Improving Dialogue with Conumnniei." written by Caron Chess. Bilbe lo Huce. ud Peter Sandman of die Environmental Commun..-.
 Research Program at Cook College. Riagen Uaiveniiy. 19S7.

        1A slide comparing cancer rlskjrom industrial emissions with, the rlskjrom. diet soft
        drinks] pnwoked.a lot of negative reaction. People said ^ can choose to drink or not to
        drink diet coke, but I can't choose not to breathe.' Nobody Is gotng to make a decision on
        a smelter based on how the risk stacks up against the tngesUon rlskjrom saccharin tn diet
        coke.' Randall Smith. Chief. Hazardous Waste Policy Branch. USEPA Region X.
      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 la seven! different ways, nuking sure not to evade the risk
      question. People whose «*»<"H* aie not already ™^» up are. very frifT*iM"**H by how
      data are presented. Because no presentation of risk to entirely objective. It may help to
      present risk In a variety of ways, expressing it both in terms that might make the risk
      seem larger and In other terms that might make the risk seem smaller. This approach
      also reduces the tendency of agencies to mtntmiyf the 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-
      tive* ex •cautious."

      5.    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 In 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 minimise or trivlaUse the risk. For ex*
      ample, tt'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 substsnces.

            a.      Use cornpartsons of the same risk at two different times, "tn 1979 before
                   regulation versus this year after regulation.'
            b.      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 is controversial.)
            c.      Compare with different estimates of the same risk your estimate of the
                   risk slde-by-side wtth the industry assessment and the environmental-
                   ists'. Then explain the differences.
            d.      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

                                                                             ftYw Mvt

      leading with an explanation of the uncertainty than watting to be confronted with it.

•iBproviag Dialogue wnfa ConunBaiue*," vrioea by Caraa Chat, BOlie Jo Hiaee. and Ptter Saodnan of the Environmental Conmunicaiioa
Rueanfa Pregnm at Cook College. Riogen Uoivemy. 1987.

 •      Give people background on the 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 answer*. 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 the uncertainty. It Is easier for
 people to accept uncertainty if they can play a role in Its resolution. This approach, not
 only la likely to be perceived as fatter hut may also lead to better solutions

 •      Give people as much individual control as possible over an uncertain situ-
 ation. Give people something they can do other than wait. At a minimum, give them a
 telephone number to call for information or to report problems.

 •      Stress the caution built Into setting standards and developing risk assess-
 ments. Even though people dont necessarily like the idea that the agency isnt sure.
 they are relieved to know that you are taking a protective approach in response to the

 •      ff people are demanding certainty, pvyattentira to values and other con-
 eerns. not just the science. When people demand certainty, the underlying issue is
 often a question of values and process, not merely science. The demand for absolute
 certainty can result'from frustration because agency representatives failed to involve
 people, did not listen to their concerns, etc. When confronted by a demand for cer-
 tainty, back up and listen to the concerns behind the demand. Consider working with
 the community to address those concerns.

 •      Acknowledge the policy disagreements that arise from uncertainty. At-
 tempt to **p*aiT» aTii^ clarify **** ••»•« of Ht«affr»m»i>  When ***** disagreements are
 about Judgment calls or management options, rather than science, it is usually not
 helpful merely to argue the science.  In addition, agency credibility is likely to suffer
 from highlighting limitations of "opposing" scientists.  Arguing Issues can be productive.
 but attacking individuals is likely to elicit hostility from those who respect them.

 7.     Recognize that communities determine what Is acceptable to them, not the
 agency.  Agencies realize that even with unlimited funds they could not reduce most
 risks to zero. While communities need to appreciate this reality, agencies need to
 appreciate that "acceptable risk" Is a relative term. The more agencies try to impose a
 definition of "acceptable" on communities, the more communities will resist that defini-
 tion. (See Chapter I.)

 •      Don't confuse people's understanding of a risk with their acceptance of It.
 People can fully understand the nature of a risk but not want to live with it

 •     To the extent possible, build In ways for people to have control over the
risk. Because people feel more comfortable with risks over which they have control.
 "We succeeded in communicating that Itfe's not perfect In the way government makes
 •_ but what wff arc doing at ct mtntntont Is sfuu tiy the' entire problem we Jocc with the
 public.* Randall Smith. Chief. Hazardous Waste Policy Branch. USEPA Region X.
 •Improving Dialogue with Commuaiiies.' wnnca by Cvoa Chen. Bilbe Jo Htace. tad Peter Sindnaa of the Environment*! Comiminicaii
 Research Pragma u Cook College. Ringers University. 1987.

       •Value Judgments are part of the risk assessment process, but if you are part of defining
       those Judgments and those decisions then the outcome ofttis something you can OTIS L"
       Lois GIbbs. 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 reel
      more comfortable with them.

      •     Acknowledge that there are other aspects of decision-making besides risk.
      and be piepaied to listen and address people's concerns.  People will often argue
      about risk when they're as concerned 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 concerns.

      •     Help 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.

      8.    Take erea greater eare presenting technical information than presenting
      other iiifbiiuatioa. Many of the keys for presenting technical information are the same
      as those for presenting i^tfr intff***>*nr*r* but are often overlooked.
      •     Know jour audience and gear your presentation to its level. Hunk 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
                                               ractice your presentations. Role-playing
          SJBO 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 wont get mlslmpresslons. 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 rw*+

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

      •     Use as down-to-earth language as possible.  Watch Jargon and acronyms.

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

      •     Choose supporting graphics that Utastrate your message clearly and simply.
      tt» fvutftntiq. atyitij ««tnj thy qpntf* graptH^iy i|ger graperies' win not go
      over well If they do not deal with people's concerns.
       DiilofM rah Gmnamitie*." written by C«aa Chen. BfllM Jo HMC*. ud Pact fandnun of the Eavaoamaul Co
Reran* Ptopim « Cook Colkge, Riagm Urivaiiqr. 1987.

 •      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 qnestlon-and-answer periods after presentations.

 •      Critique your presentation afterward, so you em leans from the things you
 dUdgataa well as. those you did wrong.
•      We still don't have a clear ways to explain very complex Information. If
we Aid, It's 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 environmental health risfcs fn
              ^m^ ^^^^^ ^^^^^-^^^ ^Bt^^^^^^m^— ~— — -^- -- — • -. - •_ ---- •_.— •• ____
              896* CBFTT CBnlpCW Onsflv rtSKS tO 4JU10T flStCS III peOflO 3 IIVCS*
       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.  The section on comparing risks in
this chapter gives examples of some useful comparisons. Further research is being
done to develop and test others.

•      Jt £» difficult to tee why on agency should admit uncertainty when people
will use such admission* aaainst us.

       This chapter suggests that people are already alert to uncertainty.  Failing 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 with Commuuiiei.' wrran by Carte- Chess. Bilbe Jo Htnee. and Peter Sandman of the Environmental Commiinicaii.-n
 Research Program at Cook College. Ruigen 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 have enough time and resources to do risk communication.  Risk
      communication does take time and staff. But if yon dent devote efforts to interacting
      with the public, you may be farced to mop up-ccmmtuiicatlona disasters—which typi-
      caDy takes more resources.

      Suggestion: Train 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
      people a chance 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.

      Suggestion? Pay as mutls 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 have solutions to environmental
      health problems. Problems can seem easier to deal with when coupled with solutions.
      But failing 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.
     0.     These issues ore too tough far 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
                       01 UlC
"Impnvui Dialogue with Gaamhie*.* wiraea by C*n Chen. Billie Jo Hince. ud Peter Sudnua of the Eavitoaineoul Commuaiciiioo
Resevch Propim « Cook Callcte. Rogers Uaivenhy. 1987.

 6.     Technical decisions should be lejt in the 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.     JMsfc 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
       If we giue the j"'*»"" an. inclu they'll take a mile. If the interaction with the
      unity more closely approximates a battleground than a discussion, this may be
true.  But tf you listen to people when they are asking for inches, they are less likely to
Suggestion: Avoid the battleground.  Involve people early and often.
9.     If we listen to the public, uie toill 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 ont the public is likely to cause dlsliuat 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 for 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 Communities." wrmea by Caroo Cheu. Bilbe Jo Hance. and Peter Sandman of the Environmental Comiminicaiion
 Research Program a Cook College. Rmgen University. 1987.


                 Environmental Communication Research Program •
                  A program of the Agricultural Expertment.Staflcn
    Cook College • 122Ryders Lane • New Brunswick • New Jersey 08903 • 201/932-8795

       Take a good look at most.rtskccnnmunication "horror stories" andyou'U proba-
 bly find.a major breakdown in trust between, government representatives and the public
 they are supposed to serve. The next, time someone cornea with a sob story -
 about communicating with the public,you might want to hand them, this tongue-tor
 cheek list. Or. better yet. hand It out.befooe the damage Is done...

 1. . Don't involve people in decisions that directly affect their lives.  Then act de-
     fensive when your policies are.challenged..

 2.  Hold onto information until people are screaming for it. While they are wait-
     ing, don't tell them when they will get 1L Just say; These things take time.* or 'It's
     going through quality assurance.*              .....

 3.,  Ignore peoples'feelings. Better yet. say they are Irrelevant and irrational. It
     helps to add that you can't understand why they are overreacting to such a small.
     risk;.                     .    -.   '••'..:", '•-'•': • •       ;

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

 5.  If you. make a mistake, deny it. Never admit you were wrong.

 6.  If you don't know the answers, fake, it.. Never say "I don't know,"

 7TV Don't speak plain English., When explaining technical.lnforniation,:use.profes- ...;
  •   sionaljargon... Or. simplify so completely that youileavroutimportant Information.:./
     Better yet. throw up your hands and.sajr. "You people,could.notpossibly under-  '•'"•'
•.   stand thisstuff.'            .-•"•••   •  /••-  •/;"'.-  '.' .;  '   '     .•-,.-">

 8.  Present yourself like a bureaucrat.,.Weara three-piece, suit to a town meeting at"
     the local grange, and sit up on stage with seven of your colleagues who are:dressed ,
     similarly. .                         •".:''.'•

 9. . Delay talking to other agencies involved—or other people involved within your r
     agency— so the message the public gets as confusing as possible:.

 10.. if one of your scientists has trouble relating to people, hates  to doit, and..
     has,beggedinot to, send him or her out: anyuiay^Jfs gppd.expeilence.,,.:.  '.-.." .
                                .     .     .<•   •••.••"..'.        •••••.
                                        •       '    ... i    ••        -.
 Froar.C, Chess/ Hance,  fl.J. f and. Sandnatt:;..-.P;,M»v. . Bivisioa. of-'Science, and- tese^cBtty.M3y•papteT.:;Qg'.gjg.'B!fcgan«TOia» 1.1>rotec»i:'?Tfv .1 >87)
                                    45     •  :: :"';"-'    '  '   •           •••%: '


                      WASHINGTON C C  20450
                                            TUB ADMINISTRATOR
Honorable Henry A. Vaxaan
Chairman, Subcommittee on Health
  and the Environment
Coaaittee on Energy and Coaaerce
House of Representatives
Washington, O.C.  20515

Dear Mr. Chairman:

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

     Thank you for your interest in this matter.

                             Lee M. Thomas



 Please provide a cable comparing risk levels which have supporcea
 regulacory actions under *CKA, TSCA, che SOWA, Clean Air Section
 112, and oche.r provisions of che Clean Air Ace.  -Please explain
 any  inconsistencies in EPA's views on che 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 and
 Recovery Act, the Safe Drinking Water Act, the Toxic Substances
 Control Act and Section 112 of the Clean Air Ace.

     Table 1 addresses che levels of population and individual
 risk that led to regulation.  'Table 2 gives information on the
 residual risk remaining after regulation.  Although you asked-that
 che  cable include ocher CAA provisions, che pollutants addressed
 under them are not generally carcinogens and their risks are noc
 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 noc to regulate are made with
 the expectation of revisiting the issue, later or are elections to
use an alternative regulatory mechanism, rather than conclusions
 chat regulation is unnecessary or that existing regulations are

     It is important co recognize chat uncertainty, often great
uncertainty, generally underlies calculations of risk from chemi-
cals in the environment.   As a result, we attempt co 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 dirrering estimates of the risk from a given chemical
or activity.  The estimates themselves span more than a decade and

 -echodoLogies for assessing coxicity and predicting exposure have
 evolved enormously ever chis cime, as have che assumptions and
 data we use in applying chese raechods.  Because exposure pachways
 differ among che environmencal media, and for various program
 specific reasons, chere are also differences in raechodologies,
 data and assumptions across programs.  As a resale, one should be
 caucious in making comparisons among che escimaces in che cables.

     Over che pasc few years we have moved vigorously Co assure
 che quality of our risk assessments, and cheir 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 (IRIS) will provide the Agency's current view
 of che coxicicy of any chemical in the system.

     While we are conducting a broad range of research co  increase
 our underscanding of environmencal risk, much uncercaincy will
 remain in che short* run and some will endure no matter how much
 research we do.   We muse inevitably make decisions co protect
 human health and che environment in che 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-
 \ble risk in risk management decisions is a complex one.   Part
 ;f 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 che economic and
 other benefits of chemical use.  The Safe Drinking Water Act
 allows consideracion of costs and other factors in setting contam-
 inant levels (MCLs), but requires chac goals (MCLGs) be based on
 healch risk alone.  Complexity arises not only from differences
 in the degree to which other factors can be considered with risk,
 but 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 EPA 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 co reduce risk can also be a faccor  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 19U2 was basea upon a
1984 comparison of increased refining costs with benefits in  the
form of reduced vehicle maintenance, becter fuel economy, reduced
emissions of HC, NOg and CO, lower levels of lead  in  children's
blood, and improvements in adult blood pressure.

     In management.decisions abouc 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 sec of
factors considered.   Nor can they answer the question of precisely
what risk will be acceptable in the nexc 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.



 l.  Maleic Anhydride
 2.  Fugitive

Vinyl Chloride

1.  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)


 Mot  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
(casea/yr)   Risk












  n school  labs
Regulated (as
calculated in 1979)
Addressed by CPSC
 > 6x10-4
 .isting of Haz-
 rdous 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 — 10
5 — 10
5 — 10
< 5
< 5
< 5
10-3 — 10-8
10-4 — 10-8
10-4 — 10-8
10-3 — 10-8

   •"able 2  Risk Levels for Regulatory Decisions
                                                       Residual Risk
   Risk       Population  Maxisurr.
   Avoided    Risk        Indivii-.
fcases/yr)(cases/yr)   Risk

A.' Maleic Anhydride  Not to regulate
3. Fugitive

vinyl Chloride
A. Emisssions  from
  EDC-VCM plants

   Emissions from
  . VC plants

Inorganic Arsenic
A. Low Arsenic
  copper smelters

3.  Glass
                     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
            7x10-5 —


 Differences  Between  Expert  and Public
 Rankings  of Environmental  Problems
      a 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.
      a 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.


      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.

      O 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
        expeits ranked mem quite high.

      Q 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?

      Q The subject is vast, and it is hant for anyone to have fun knowledge of h.
•Difference! Baweeo Expert and Public Rankings of Environment*! Problems" prepared by (he Environmental Prouoion 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.

       Q 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 loag time, the presence of an trf?m(fi^hiy. "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.


       Q 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

       Q The differences raise an important issue for a democracy. Put crudely, should a
         democracy focus available resources and technology  where mey 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

       a Contact the Office of Policy. Planning, and Evaluation or the Office of Policy
         Analysis (202-260-4012) or (202-260-4012).
'Difference Baweea Eipen and Public »•-"•§• of Environmental Problems' prepared by the Eavaoamcaul Pnxecuoa Agency: Oflur .
Policy, punning, and Evaluation.

                           Perceived Seriousness of Some
                                Environmental  Problems
   Active Hazardous Waste Sites
   Abandoned HiTarrtnm Silei
   Waiter Expasam to ToxJc*
   Radioactive W«U
   Underground TanJt Leaiu
   PtfliddtsHann to User*
   Pesticide Residue
   Industrial Accident Pollotioa
   T*p W«cr OMURBHUO*
   lodntrid Air PoUatioo
   Ozone L«yer Dejuuaioa
   Ocean. Catsui Wiier
   Sewage Plant Water PoUuuon
   Vehicle Eitwut
   Oil Spilli: Tuken. Rip
   Acid Rait
   Urban Run-Off
   Damned Walinds
   Cnetic Alter . Damige
   Noo-Haunlau* Wa«e Site*
           e' Effect
   Indoor Air PoUuuoo
   Indoor Radc* Ail PoOatica
   Microwave Ovea Radiauoa
                                       Don't Know
                                       Somewhat Serious
Not Too, Not at All
Very Serious
•Differences Between Expert and Public Bmfci«|« of Environmental Problems^ prepaied by the Environmental Protection Agency: Office of
Policy. Pluming, and Evaluation.

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

   ^  Lethal  Legacy  of  Lead   Poisoning
Lang After a Battery Plant Shuts Down, Contamination Lingers in Soil and Bones
                       THXOOP.Pa.   jg^-.

      From morning to night, far 14 boon
      Straight, RttdCSttflff Dtt OOrtnCUt
      PoiuijrlviDii fnnvt*iiT"'y trrifcd it
      the loot ugh school for medial
test* -bey feared would uncover a  tanf-
burir prJriem.
  M ,vj)j slowly from gymnasium to dan-
roar, they fined oat health hauries. cave
blool and were  subjected to a tatterr <*
tests to measure suds thmga at nerve re-
sponse and motor sldlb. The final stop wa*
a 35-foot-iong Chevy van parked  oeirbv.
Tjere. each readent slid his or her leg into
i new X-ray machine that screened then-
bone* for lead.
  After fire dan of teamj. John Rosen,
aaeaitbc nation's leading experts OB ciukf-
hood lead pouonng. announced the results:
One third of the 200 residents he tested had
elevated levels of lead • the* bodies. Many
of them were children.
  For yean,  resident*  had  wondered
whether  the old Marjol Battery A Equip-
meat Co. wi» poiluimg their town.  Black
cloud*      ike had bdcbsd from the b*t-
teryt,      punt and wafted over nearby
naghb.     E. Acad-nata had eatca hale*
throng* dothng hangmg OK to dry.
  Yet even when frri contammatiQ*. w*»
found • nearby rarda and atreetf m 1975
and igam in 198*. government envnon-
meutai official* had aaared rodents there
was ae health problem. Not trusting the
affiant assessment,  they sought the he* ol
Rons*, woo told them tbe
reansoe. Tbe problem.  Roaoa
  •A Lkui nHAn.^MM  • Ww^^Mt w.
was Man pomoDDf. a wooen an
problem that ought affect oxmtien dot-
Arm *nd xhifrm ip otK»» frwnii.iiiiifx •
  Lead is a highly tone materaL QnldrtB
1TC p*VllCUl*Uiy iUBLJCpODaC  OBQflaV  CDC
octal can damage the growmj oenrooa ar»-
                                     TOO tare to k»f
                                       And  that i* when  the

                                     their answer*. The SUiuiV fannqr

                                     Marjol sde m  1979. "We did a.becaoa* it
                                     wa* *ach a tag plac* and we bad a |
                                                 EFA foond Inda of 1000 to
                                                 tg miiiaa m Thnon. Scbora
                                                  ef 8.000 parti per naffioB in
                                                net ihadfd yard.
                                       The Hanoi site and the uaiuumiing area
                                     vox deaiapated for deasup unber the fed-
                                     eat Superfund law. Beenrons in 1988. the
                                     yasot of tbe 81 homes were excarated to
  •We tad *
had been oHymg in a hanvf .-—	
**^"^f'""?****.* Uwd N ICUQnM MBtOnV A MtUUUI
psycbologiat and  father of four children.
•We wanted aorwer*. and we  didn't trust

  Throop's search tor «an»w*r ted rendeas
lead i* the bone*.  Tradnonaly, doceonhm

the bknd only 30 to 45 day*.
  •Nin**-five percent of th* body  burden
oftr      «d in the bone*.' sad Andrew
Tot       a»r oi mefflcai peyaa « the
           r aboot Manoi'a:
the on*, about the kad ant bad becnioand
• thnaod of neighbors' yard* back-in 1975.
But they also knew that then- danghten.
Jun* and Dint, tad been among th* 200
children m town who, a* part of th* so**'*
 	m PHI of Mario! in 1975. tad received
blood test* that revealed DA probiem.

QMt Mtnltft DcptftSMtnt oi  EnnnDDfOBteU *•**
       told n* to cow oar lawns wrt
topnoat  and  replant. The  lead, they anA>
                                     wandodared totatty unsafe. Several motto*
                                     ago* a  iinm rtrf rUa*i*rf the. interior of 60
                                     boose* to cemove lead dust.
                                       Tn* cknmm. now ~"-«"^ at $11 maV
                                     Son, is bang paid for by th* Gould Corp,
                                     which bonffct tte Marjoi sae after the pant
                                                                              Bat wink  EPA
                                                                            that sai aod	
                                                                            they mamuiocd there wns no health prob-
                                                                            lem for  rendnnt*. And. mdnsd. another
                                                                                  of  test* aopearad to support that
                                                                                  p^^ t*«t* i'w**iMf*»A OQ 300 dnW
                                        In 1976, after repeated
                                       enanment ordered Manoi to
                                    formed Halt Environmental Lead Pollution.
                                    HELP, which persuaded several of the oa-
                                    bon's leading experts in childhood lead poi-
                                    'soaiof, including Rosen,  to counsel them.
                                    Tbe group rented a van  and in late 1989
                                    started  ferrying  people 120  miles  to
                                    Rcaen j clinic in the Bronx, where he was
                                    conducting bone-lead studies.
                                      *I really didn't know what to ••p*"** re-
                                    called Rosen, tmt 1 was shocked.' More
                                    than a third of the 75  Throop residents
                                    Rom bad-elevated levels of lead in their
                                    bones. He decided to go to Throop.
                                      Last June, Rosen  and fire  trrhniriam
                                    ^ ,-...«.< an nMjtu»iji 12? r*«uif*it* here
                                    aod conducted neurologxal and learning-de-
                                    velopment testa.
                                      The preliminary resulu indicate that a
                                    highly significant  percentage  of  resident*
                                    across a wide age range  have dear-cut ev-
                                     idence of lead exposure that occurred ear-
                                    tier ML thor lifetime.' be said.
                                      Those  with the highest level of lead ex-
                                     posure had grown up during the yean the
                                     Minol plant was operating. Nearly two
                                     thirds of the teenagers who were tested bad
                                     high lead levels.
                                       Diana  Schocts, 16.  is  among them.  Ai-
                                     thoBgfa her mother said she has no medical
                                     proWems, Roaen'a tests found that Diana
                                     has 57 pant per million of kad in her bones.
                                       Them are no standards yet for how much
                                     lead in tn* bones poses a  threat, but Oiana'a
                                     level dearly was remarkable.  Todd.  tbe
                                     Uuivciivy  of  Maryland researcher,  has
                                     round an average of 30 pans per munoa at
                                     lead-smetter workers in Europe.
                                       Lead f*fb» are  generally inhaled or
                                     m gated. then find their way into the Mood-
                                     strctm and are finally absorbed  by  ttae
                                     bones. Ones locked in the bones, ttaey do
                                     not pnmnt an immediate threat. But the
                                     resent of the tenon on be released under
                                                              I too* tne<
          . In 1982. the <
doMd tor food. Tnt i
Of TOTOOp s prooiesn.
  Bat in 1986. the federal Environmental
Protacoon Agency came to town, tested the
sod and shocked residents by irmmmnng
that the yards of the Scfaom home and 80
others wen heavily j /miHinmlM
  AttOfdmc to the EPA goiddiDe, ttdwttfa
         SO p*ra per tmiiiasi of lead nogtit
dren dkt not reveal any elevated exposure
  Bat tni* dD* msuy people beie renswd
to bUkiie everything was all right.
  Throop, a modest community of  frame
and brick homes where tndmonai values
p~*~"""«» was not a likely candidate to

  But tbe shock of bong declared a Super-
fund toe a dozen years after the state had
and mem wn no problem weighed heavily
                                                                                     Scnort* and  40 other
  For enmpte. lead is released if a bone is
broken, if the ndwihial o bednodea for a long
one or if he or *e suffers bone disease.
  A serions release could occur  if Dims
were to have a  baby. Rosen waned  th*
Schorae*. Because mothers' bones are tn*
source of calcium for the fetus, there i* a
rak of i' mi nriilly poisoning tbe fetos.
  Rosen advised the Schora family to mon-
itor Diana's blood-lead  levels and kidney
function in future checkup*, because kad
can easuy impair the kidneys.
  Penmytvima official*  have link to say
about Throop. "Our understanding of the
problems of lead are so  much greater now
than when we mioally looked at the problem
in 1975.' said Susan Wood, a spokeswoman
for  the environmental  resource* depart-
ment. "But it waa the state that suggested
the EPA go back and take a second look.*
  Officials at die state Department of Health
ay flat the X-ray technique a eniaiiueBUl
and that the result does not demonstrate that a
health problem enats. There are no compa-
rabk xudnt to chow the bone-lead level* in
me general pnpnlarMi.

                    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 much 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 aa 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 news 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  -  "What  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 the National Conference
on Risk Communication.  Edited by J. Clarence Davies, Vincent T.
Covello, and  Frederick W. Allen (The Conservation  Foundation,

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

    2) DO ask which topics they want to
DONTteU. the news organization which'
reponer 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.)
DONT insist that they promise not to
ask about certain subjects.
    4) DO ask how long the interview will
      be and what the format will be.
DONT demand that your remarks not
be edited.
    5) DO ask who else will be interviewed.
DONT insist the reponer not interview
an adversary.
    Prior to interview/news conference:

    1) DO obtain accurate information and
      be completely honest.

    2) DO decide what you wane 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                    67
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.

11) DO state your points emphatically.

12) DO correct big  mistakes by stating
   that you  didn't  give  an adequate
   answer and you would like a chance
   to dear up the confusion.
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

DONT ask reporters for their opinions.

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-

 18) DO try  to be as open with the me-
   dia as possible.
 DONT 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.
DONT hesitate to refuse to give propri-
etary information.
DONT give  one  reporter exclusive
After the Q & A:

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

2) DO remember, it's ail 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       DONT let sleeping dogs lie.
   in the Q & A.

5) DO volunteer to get additional  infor-       DONT refuse to talk any further with
   manon reporters need.                   reporters..

6) DO tell reporters to telephone if they       DONT ask "How did I do?"
   have any questions about something
   that you said.

7) DO volunteer to  be  available if a       DONT ask a  reporter to show you a
   reporter wants to go over something       copy of the story in advance of publica-
   with you.                           .     tion or broadcast so you can correct it.

3) DO call reporters  if stories appear       DONT call the reporter's boss to com-
   that are  inaccurate,  and  politely       plain without  first speaking  with  the
   point out what is wrong.                  reporter.

                      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) Failure 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.

Kuk Analysis. VoL 10. No. 3, 1990
What Do We  Know About Making Risk  Comparisons?
Emilie Roth,1 M. Granger Morgan,*-' Baruch Fischboff,2 Lester Lave,3 and
Ann Bostrom2
                          Rtctntd April S. 1990
                          The risks of unfamiliar technologies are often evaluated by comparing them with the risks of more
                          familiar ones. Such risk comparisons have been criticized for neglecting critical dimensions of
                          risky decisions. In a guide written for the Chemical Manufacturers Association, Covello « a/."*
                          have summarized these critiques and developed a 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  Covello et oL as examples of
                          their categories. We found no correlation between the judgments of acceptability produced by our
                          subjects and those predicted by Covello a aL.
                          KEY WORDS: Risk companion; risk eamnunidiioa; risk perception.
     A tempting way to describe the risks of hazardous
technologies is by comparison with other, better known
risks/3-3) such as: the cancer risk of living at the bound-
ary 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,'*' such comparisons
have come in for considerable criticism.15"7' 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
penuade 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-

'Westinghouse Science and Technology Center, Pittsburgh, Puuuyl-
vinii 15235.
•Department of Engineering and Public Policy, Ctmegie Mellon Uni-
versity, Pittsburgh, Pennsylvania 15213.
To whom correspondence should be i
torical arguments ignore critical elements of people's
risky decisions, such as how voluntary the choices are
and what benefits they are expected to provide. Because
people perceive risks in multiattribute terms, the fact that
a risk bias a low value on a single focal dimension (e.g.,
estimated fatalities in an avenge year) does not imply
its acceptability.<*> 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 spokespeople avoid
these pitfalls, Covello et aLm developed a manual ad-
vising plant managen on how to present risk compari-
sons so that the public will  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 risk communication literature.  It provides, for the
first time, an analysis of the different ways that  risk
comparison statements hive traditionally been  em-
ployed, and offers a framework for evaluating them.
Covello et aL  enumerate 14 commonly used types of
risk comparisons, which they then group into five cat-


to lay people (see Table  I). The manual  recommen'ds
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 a 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  a aL *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 et 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 a aL is suggested by the  following quotation.
   The highest-ranking comparisons ire assumed to be those that
   put the least  sown  oo the  Bust relationship bttwuui a puuu
   manager and the public. These oonptroofls trad to svikc even
    skeptical listeners u relevant, appropriate, and helpful infor-
    maiion. The lowest-nnkiBg comparisons, on the other hand.
    are those that hive oo intuitively obvious diim to relevance,
    appropriateness* or helpfulness. Such comparisons are more
    likely to be seen u manipulative or misleading—that is, u
    efforts to preempt judgments about the acceptability of the risk.
 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
 etaL's definition of "acceptable." These scales appear
 in Table  n.  Scale  1 asks about how dear 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 7 provides  an overall measure of acceptability, by
 asking whether the  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 u with Covello a aL '$ predictions.
 2.1 Method
      9  '

 2.1.1. Partidparas

      Four groups participated in the study: (A) second-
 year graduate business students (N" 13); (B) members
 (or their spouses) of a suburban garden club from a raid-
                          TiMc L Govcllo a al. Risk Compt
i and Ranking System
Pint-rank risk companions
   1* Comparisons of the sime risk at two different IDCB
   2. Comparisons with • standard
   3. GompansoH with different csomtca of OJG ttne IBM
Second-rank risk companion (iccoBd fhoirf • If is desirable)

   '. Companions of altenutrve solutions to the sme problem
   6. Companions with the same risk as experienced in other places
Thiiu-iank risk compansoni (third choite  even less desirable)
   7. Conparuoos of avenge risk, with pc&k rak ftt • [
   8. Compariaoai of me risk bom one source of • particular advene e£Eea with the riA from aD aooren of ttat sane tdvene effect
Fourth-rank fjjjg comparisons (fourth choicf • tBURimlly iccEpttblc)
   9. Comparisons of risk with cost, or of GOB/Mik mio win con/risk ndo        •  •
  10. Comparisons of risk with benefit
  • • ^»^^^^^^«^^^ — •»«. ^^ i»^_ ^HI^ J^^^K «A»A B^^KK AA—^BB A_— A.. ^_ ^u. ^  m __ -••• — .__
  12. ypfflpimffBi WIIB oiocf ma DOB IBB HDC •MBOC* BKD • lac mnc ttoiiiy of

 lnBHWlk fffftH[Mf1aHTni (Itft CDOIOiS^liBCijf MGBpttOla*WBfliK W||D C9DCBM GUlOOBJ)
  14. Conpvisons of onrclitcd risks.

 Making Risk Comparisons
                                      Table II. Scales Used to Rate Covello a at. Suiemeatt.
                   This statement ii dear, easy
                   to undenund.
                   This  statement wflj help
                   townspeople to better un-
                   derstand the nsk.
                   This statement gives infor-
                   mation needed by  towns-
                   people in their personal
                   decisions about the risk.
                  This statement's tone un-
                  deiemphasiifi the nsk.
                  This statement is likely to
                  reassure the townspeople.
                  This statement is likely to
                  increase the townspeople's
                  mist in the plant manager.
                  This statement should def-
                  initely be included  in the
                  plant manager's  talk.
    This statement's tone cor-
    rtoly convtyi the risk,

D     D     D     D    D

D     D     D     D    D

D     D     D     D '  D
                                             This statement is  unclear,
                                             difficult to understand.
                                             This statement will not help
                                             townspeople to better  un-
                                             derstand the risk.
                                             This statement gives no in-
                                             formation  needed  by
                                             townspeople in (heir per-
                                             sonal decisions about  the
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 (AT*33); (Q members
of a synagogue (AT»28); and (D) members of a Prot-
estant church  (N-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 S10 or had  a $10 donation made to  their  organi-
2.1.2. Materials

     In order to introduce the evaluation task, we con-
vened the scenario described  in the manual into a cover
story which read  as follows:
                        rrtt* rjtfnueml plant rtlat i
   ewylcne oxide in the small midwesicm town of Evanston has
   been asked to give a talk to a local community meeting abooi
   risks posed by his plant..The local newspaper plans to reprint
   the sprech m its entirety and make it widely available. People
   in me town are concerned about the possible risks posed by me
   plant, but there is no crisis situation or serious confroatauonal
     The plant manager has been a friend of years for many years.
   He is concerned about ^alpr*fl this spcich and, as an old friend,
   has asked you for your candid advice about some things be is
   ooosidcnng saying.

     Before starting, here is some  background information: Elh-
           ytene node is nsed in ahum all hospitals and other medical
           facilities as a 
                                                                                                    Roth et 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; S °  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 a/.'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. Route Across Groups

     Table ffl shows mean responses for each statement
on each scale for all 93 participants. With the exception
of scale 4, Covello a o/.'s proposal predicts that each
successive group of statements will have higher means
than its predecessors.4 This was not found. Spearman
rank-order 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.3 None of the seven scales was signifi-
cantly correlated with Covello a oTs.  order in the di-
rection  predicted. For all  participants combined,  the
correlation with scale 7 (whether to include the statement
b 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 al. 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 a "3" was the most favorable value. Because all mean
 responses for scale 4 were leu than 3, higher ratings indicate more
 favorable responses.
'Analyses were aba performed on the rank sums for each statement.
 The rank sum  for each scale wu computed by determining each
 participant's rank ordering of the 14 statements. The rank sums scran
 me 99 participants were highly correlated, with the mean scores ap-
      ; in the table (all correlations above 0.85). The results using
 this measure were euentiaUy the same i
                 Tabk m. Mean Responses for the 14 Sentences on Each Scale (Avenge Across all 95 Paniripams)




•For scales 1
through 3 and :
{ through 7. 1 i
2.13 -
is the most favors!
Information Under/ever-
needed emphasizes risk
blc rcnofiic.
For scale 4. 1 • undem
2.44 •
Finhuizcs risk *
\ • overemohi
Should be
isizes risk.
•The statements are listed in decreasing favonbiliiy. according to Covello ttaL't predictions.

 Making Risk Comparisons
                          Tible IV. Speannin Rink-Order Comlition with (he Covello a at. Ranking*
All group
Garden club*
MBA nudenu
 •All correlations « or above .46 ut significant at toe .OS level. Correlation* it or above .65 are «•'£•'«"« at the .01 level.
Aids undemanding
Information needed
Qver/undcremphssizes nsk
Increases trust
Should be included
W- 33
W- 13
N- 28
AT- 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,6 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-
 ello et at. 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 • statement should be included (scale
 7), the strongest predictors were how reassuring it seemed
 and 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
 cases. 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 "ceiling effect" would reduce difference* between
 statements, even though  there were still statically relia-
 ble differences in acceptability (see Section 2.2.4). A
       T«btt V. Correlation Maim for the Seven Scales
1 Clarity              1.00
2 Aids understanding     0.28  1.00
3 Information needed     0.22  0.88  1.00
4 Ovw/undertBiphuixe risk 0.32-0.52-0.66  1.00
5 Reassuring           0.36  0.66  OJS -0.091.00
ClBcnuesna         O29  0.74  0.72 -0.490JO. 1.00
7 Should be included     0.33  0.71  0.73-0.360.900.911.00
 As ncntionedt higher ntiagj indicate more favorable responses on
 scale 4.- so that the negative contUtioBS there are consistent with the
 positive correlations on the other variables.
                            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 Croup

                                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.
                                EveryJcorrelation 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-transfonnation,
                           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
          were 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 et al.'s prediction order.
          The ratings of the  15  participants who received state-
          ments in Covello et o/.'s  original order  were signifi-
          cantly correlated (P < 0.05) in  three cases. Two were
          in the predicted direction,  scales 4 aad 6  (-0.57 and
          0.52, respectively); while one, scale 5 (-0.52) was in
          the opposite direction.  Overall, the weak and  inconsis-
          tent pattern with this small group does not shake  the
          general conclusion that order of presentation did not af-
          fect subjects' ratings.

                                                                                                    Roth a al.
2.2.4. An Ordered Categorical Response Model
     An ordered categorical response model, specifically
a three-level ordered probit model, was used to clarify
the differences in ratings among the 14 statements.*9-1017
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
"3" on others).8 The model was estimated in LJM-
DEP,(n> 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 a al. ranking system, even when
effects of scale, order of  presentation, and group are
statistically controlled. The beta coefficients typically
had the wrong sign (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 x2 statistic from the  log-
likelihood ratio test is highly significant (727.5, 24 df,
p < 0.001) and the model correctly predicts 55% of the
                          IDU oie observed ratings ere discrete
                           BO ifitervu relation DCIWCCJI rsosg
'An ordered probit model s
 and have ordinal proper*               	
 points is assumed), but that the underlying (unobservable) dependcni
 variable (i-e*. statement acceptability) b) coBonBOBB asd BOfnaUy
 -M—.—i.——-. rMMirlitinn.l JM. ftiA IM«J|MMJ.^ .JMMakl^M
 uisuiDuico. onnflitionai on nc preoioove Tanaiuca.
The original five-print ratinp for aD teaks, except 4, were also fit
 with sn snalogous model as was an alternative 3-poiat set of collapsed
 ratings (0 - 1; 1 - 2J,4; 2 • 5 to all scales except 4, which was
 collapsed as above). Similar results were obtained and are available
 Bpon reojuest.
44      «J     M     M
                              M    M      0-i     '•»
Fit. t. Estimated beta coefCcieats (or (be statement dummies from
the ordered probit regression modclj witb 95% confidence intervals
marked (based on the coefCcient's estimated  standard deviation).
Statement 14 is ihe base case (intercept).

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

3.1. Risk: Comparisons Deviating From  Predictions

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

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

 Making Risk Comparisons
 not include cancer  (e.g.,lightning). 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 a al.'t 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 on all their risk features
 (not  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 at. *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
  ocus on the magnitude comparisons in the statements.
 These were, in turn, executed  relatively well. If that is
 the case, then, in effect,  Corvello a al. foiled their own
 prediction when they created the illustrative statements.
 3.7.2 Comparison of Occupational with Envinmental
 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
 al. 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

 inappropriate outside of working life.
     However, although Covello etofs statement 11 does
 refer to occupational and environmental  risks, it does
 IIQ* invite risk—benefit WM^pffl***- Rather,  its main tfaurst
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 Expected

     Covello et al. 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 on six of the seven scales. They were among
the worst three items on scale 1, measuring how "clear,
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 my have been particularly difficult because it included
small 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 pionabflitifs, had SOUK of the worst
ratings on the clarify scale. Apparently, we still have
much to learn  about presenting such information.
     A second possible source of  confusion in these
statements was the need to integrate the multiple per-
spectives that  they presented. For example,  what are
recipients to make of a risk that meets one of  several
standards, especially when they know little about the
organization that set each standard  or the purpose for
which it was set?  Similarly, bow are they to recocile
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

                                                                                                  Roth era/.
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 a o/.'s pre-
dictions may have failed.
3.2.1. Flaws 01 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 limit* 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 o/.'s theory, there are two  obvious
places to work oa: its classification scheme and the pre-
dicted rankings of its categories. Covello et a/.'s clas-
sifiottion scheme sorts 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 era/. It is, of course, possible
that 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
ofs predicted ranking indicates the need to clarify  the
goals of risk comparisons  as well as to study  how to
reach them.'

•Any other feature of our memom procedure might aba be ailed

Slavic a a/.iu> wonder tbont whit would hive tappned had we oted
•Bother covet stoiy. Piuyieu here nquifei icoou&tiBK for boch those
putens Uut did emerge in pieviuui cmdift n well is te tone thu
did net.
3 J. Toward • Systematic Classification of Risk

     One significant contribution of the Covello et al.
proposal is describing the variety of features of a risk
that cwpariMB statements can highlight  Indeed, each
category in their system deals with a different aspect of

while leaving die communication of absolute and relative
magnitude to other statements. It seems unlikely that any
criterion of acceptability could apply to messages having
Bach a variety of purposes. Each is legitimate for some
purposes and  flawed for others, with its acceptability
depending heavily oa the quality of its implementation.
     One way 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 matter 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
 •idgments of risk acceptability.'11*14) The fact that these
 tributes 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 h 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.(U>lt> 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
ire just like tobacco company scientists").
3.3.2. Determining the Values on Risk Attributes

     Once the attributes relevant to a decision have been
identified, decision-makers must determine  how each
option rates on each attribute.  Conveying information
about the magnitude of consequences is one clear pur-
DOSC OX JISK COIUfflUPl CfttlOflS* y\fi •9COQOOCO* IttK 00^0*
parisons might be a useful tool for doing so, by providing
 a familiar point of comparison for an unfamiliar haz-
, aid—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
 noncoercrve suggestions of alternative perspectives."7'
 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 et
 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, fly different means are sometimes classified
 separately. For example, statement 11 uses the experi-
 ence of plant employees as an upperbound  estimate of
 me 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 mother.
      Category 4 ("comparison of the risk of doing some-
 thing versus not doing it") provides another example of
 a category that includes comparisons with varied  con-
 tent. For example, ft 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.
                                                        4. CONCLUSIONS
                                                                                     ated and classified a va-
      Covello et al. have enu
 riety of risk comparisons. They were not, however, able

                                                                                               Rothet oi.
 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 et a/.'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 ethylene oxide at
our plant are 40% less than a year ago, when we installed
exhaust scrubbers. With more equipment coining 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, I am providing my work and 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 this 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 Evanstons 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
living in Evanston 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 on the laboratory mice
most likely to develop cancer in response to  ethylene
oxide—and calculated first the lowest dose that caused
advene 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 maximum can-
cer risk to people m the community is 0.007 cancers  per
3500 persons over 70 yean."
    "Our worst-case estimate of the risk is seven thou-
sandths of a cancer per 3500 persons over the next 70
yean. How sure are we  that the risk is really mis km?
The bad news is that we're not as sure as we'd like to
be. Risk assessment is a pretty new science, based on
models and assumptions rather than hard data. The good

 Making Risk Comparisons
  ews 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 an extra margin of safety. And here's a piece of
 hard information.  We've been manufacturing ethylene
 oxide in Evanston for  35 yean now. We have contin-
 ually monitored our employees for signs of advene health
 effects associated with exposure to ethylene oxide. In all
 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 Qub
 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-
  ase situation is that  the maximum total risk will be
 J.005 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 wont-case estimates."
Statement 5

     "The maximum health risk from our plant's emis-
sions of ethylene oxide is 0.007 additional oncers 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 ethylene 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  living 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 ethylene 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 S2 million to reduce our already snail emissions
                                                 even further. This new investment will bun us econom-
                                                 ically but wfll reduce the risk of cancer in the community
                                                 by more than  25% when fully operational."
eat 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 etbylene 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
Statement 11

    "One way to look at the data is to compare the
risks of emissions of ethyleoe oxide to plant neighbors
with the risks to plant employees. We have been oper-
ating this plant for 35 years, with an 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 enrimiom
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. One chest x-ray per year presents a
risk of developing cancer that is twice that of developing
cancer from our plant's emissions of ethylcx
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 (he 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
American of death from lightning is at least 140 times
.greater than the  risk of cancer in Evanston from the
highest exposure to ethylene 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 Annan, C Cortes, G. Hester, R. Lio,
L Nair. and P. Steranchak for their assistance in this
work. We received helpful comments on a previous draft
of the manuscript from G. Hester, J. Men, D. Resendiz,
P. Sandman, and P. Slovic. The work was supported by
National Science  Foundation grant SES-871564. The
views expressed as those of the authors.
 1. V. T. QwcUo. P. M. Sodmu. nd P. Sow. Ktk Commuri-
         ffirt Tmriirt i. iiri fffrt rnmjMn«u I Mmmtfar fhm

Making Risk Comparisons
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 Risk Analysis. VoL 10. No. 3, 1990
 What Should We  Know About Making  Risk

 Paul Slovic,2 Nancy Kraus,2 and Vincent T. Covello3
     The study by Roth a al. m provides • valuable
 lesson for risk communicators—lest 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 nave.
     The results obtained by Roth et 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,(U<4) they have been criticized for
 ignoring many of the quantitative and qualitative factors
 that determine the perception and acceptance of risk.'3'
 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
 et 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
 that the study by Roth a al. employed only one scenario.
 In this scenario, respondents were asked to evaluate the
 comparison statements Bom the perspective of advising
 a plant manager who is about to communicate to a con-
 cerned community in a noncnsis, nonconfrontational at-
 mosphere.  Many plant managers must communicate in
just such a setting. However, we believe that ft is im-
 portant to replicate this study within diverse contexts,
 including a setting where  the community is angry  or
 distrustful as well as a benign setting in which trust,

 1 Received Much S. 1990.
 1 Decaira Roeucb, 1201 Oik Street. Eugene, Oitfon 97401.
 • Center for Risk CamnunictiMii. School of Public HeiUb. Cohabit
 Uaiveaiiy. New Yoik. New York 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-
ments should be evaluated in addition to those drafted
by Covello et al.m. Third, we would like to emphasize
a point made by Roth et al., and to provide some sup-
porting evidence. Roth et 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.0-**9*
    We believe that these arguments are flawed and that
risk acceptability depends on a wider range of factors
than the probabilities or *TP»^*»<< fatality or morbidity
estimates that are 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
         t in which subjects played the role  of jurors
 IB A SODUUtCO tflU ID WQICD A ooirtrmiy tu&t Supplied
 asbestos insulation materials was charged with exposing
 the students and stall of a school to unreasonable nsk
 of disease. In our scenario, the company contended that
' the use of this product in the school building did  not
 POM? 8 DCUtD DBZ0Q ID "^ StUQCfltt 8DQ Sttff 01  the

                                                                                                 Slavic a al.
     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-
     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       [    ] not guilty

     Croup n 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 Irving 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  nsk comparisons in the table. Dr. Davis
concluded his explanation with the following opinion:
   So now, if we look it the risk inoriitrd with being cumd
   ID iihfiBii fibers while sttrariing Jefferson Jniof High School
   for three yens, il'i lea tbu one - 0.23 deaths per million to
   be precise. That'i i very mil friction of the risk estimated
   fgf drinking djei oodtt or even for ettng pcsm buscr tutr*
   wfchcs. Sot even though cxponfc tti sitif um 0 vy high
   levels DM been shown to cnw disease, I'd have to ay, boscd
   on my professional experience sod es s concerned citiicn, thai ,
   1 would have no concern if anyone — including persons Bom
   wy own fnuly — were 10 sttrnd Jcfhraoo Jonior High School
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-
ment by Dr.  Davis. In addition, subjects in this group
were given a statement by a (fictitious) expert witness
for the plaintiff, Dr. P. 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 IL
     Table in 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.
     Group D, 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 <
O.OS). Presented without challenge. Exhibit A was dearly
effective in reducing subjects concerns.
     Responses from group HI, however, were virtually
the same as those from group I, suggesting that the ef-
fects of the comparisons on perceived risk and judged
guilt were fully offset by the critique presented in Table
     Technical analyses of  the asbestos problem have
            BnaUl A; Ufetfme Rats per Million
                                Deaths per million persons
Snaking one pick of cigarettes each day
  far 20 yean
DiDktag one did aon drink fHHianiing
  saccharin per day IDT I ttBliDC
Living in • brick boose (i


                                        . «•
                    li«*h i
After examining Exhibit A and reading Dr. Davis' state-
                                                           3 yean (asbestos based on 0.001 fibers

Risk Comparisons
 Table IVSutemeni by Dr. P. Stewart. An Expert Witness Called
 en Behill 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 persons of
dying  from the activities listed. The numbers shown on the than are
estimates, based on statistical analyses.
  In my opinion, the numbers in this chin are misleading, and fail to
have any logical implications for the asbestos decision under consid-
  Firs, ihe estimates in the Exhibit may an be accurate, particularly
hi the  cue of asbestos. The risk value grvtn for asbestos is based oa
an average reading of .001 fibers per cubic centimeter. Bui. at times,
ike level of asbestos fibers people in the building are exposed » 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 fact thai one risk is
accepted does not necessarily mean that another, lower riak is accept-
  Acceptability must weigh risks agsinst 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 thai can provide
similar benefits.
  Furthermore, most of the risks presented in Exhibit A are voluntary
activities. Attending a school contaminated by asbestos is involuntary,
not under  the control of the children who arc  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
I wouldn't want to expose my kids even to • theoretical riak of i
if I didn't  have to.
    Table d. Perceived Risk and Judgments of Gufli for Three
                  Information Conditions*
Group Presented
Lifetime risk
Lifetime risk plus
Mcui perceived % noding ooeopuy
N riak guilty
30 3.33(2.13)
27 2.48
       Exhibit A
     Lifetime risk
       Exhibit A. and
       critique of Exhibit A 60  3.53
 Parenthesised values for group I summante 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 (heir assignments from 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.00' 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(M) and including
the study by Roth et  ol., are similarly incomplete  —
uioic on the order 01 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 not be  convincing to the
public in an 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
                          i with the asbestos trial simulations. In partic-
                 ular, we wish to thank Deny Allen, Kenny S. Crump,

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

 1. E. Roth. G. Morgan. B. Fbchboff. L. Lave, nd A. Bosnun,
    "What Do We Keow About Makiag  Risk Comparisons?" Ait
    Anafyas 10,375-387 (1990).                s
 2. F. 0. Sowby, "Radiation ud Other Ruta." Health Plytia 11.
 3. N. Rothschild. "Coming to Grips with Risk" (Address pRsemtd
    on BBC television, November 1978; reprinted in the Wall Sat*
    Journal. May 13,1979).
 4. B. Cohen, ind I. Lee. "A dialog of Risks," HtaUi Phytia M.
    707-722 (1979).
 5. P. Slovic. "Perception of Risk." Science 36. 280-285 (1987).
 6. Editorial, "Rothschild's numerate arrogance," Narurt, 276. 429
 7. V. T. CovtUo, P. M. Sandman, and P. Slovic. Risk Common/-
    cation. Ksk Statistics and Risk Comparisons: A Moiuutlfof Plant
    Managers (Washington. D.C, <>••"«' Manufacnmn Associ-
    ation. 1988).
 8. E. W. Lawless, M. V. Jones, and R. M. Jones. Comparative Risk
    XiiHJiiifiiC Tancfd* and Analytical Frame***  (Kinias Cly.
    Midwest Reseaich Institute.  1984).
 9. E. E. Pochin. "The Acceptance of Risk." British Medical Bul-
    letin. 31.184-190 (1975).
10. B. T. Mossmn, J. Bignon, M. Cora, A. Seaton. and J. 8. L.
    Gee, "Asbestos:  Scientific  Developments and Implications for
    Public  Policy," Science 247.294-301.
11. B. Foehhoff. In R. Katpenon  and R. W. Kates  (eds.). fijuuy
    laues in Nuclear Waste Disposal (Cambridge, Oelgeschlager. Gmm,
    A Ham, 1981).

UrwudSutM          Oftoof
Enwiramoui PMMMA     Toonc
Some Notes on
Environmental Risk
•>-->— mm C<*^*^^*^^
rctor M. oanoman
November 1986

                       L  BaviiaamnulfukuaataaicMory - 4
                       5.. IUponmaytopmoMlis*(tofukitafy
                       6,  CkiMofrakiMuiuaUyeaOTMwimthythiaclaiiiuofMfety -- 10
                                      aa lot mortthui mortality sututia -- 14
                       X  Policy dMuiMM* MM Mwthtriuky or Mfe ------------- 17
                       4.  Equity ud ceaooliMUMuadcriMBMtriikeoatrevtnw*             18
•ElpUiniag EBvtroomeaul Riifc  Some NCUJ oa Eoviroameaial Risk Cbmimuueanoa.- by Pew M. Saadmaa for the TSCA AIIKUIKC
Office, Office of Toxic Subnuce*. Ui. EoviroaiBenal Pmecuoa Agency. November 1986.

                      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
                     quMtkui* haven't been thoroughly studied, and, hare 1 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
                     people perceive a risk determine* bow they respond to 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 a*ay with
                     anything if they sell it cleverly enough, while advocates of
                     good policies sometimes imagine that they don't have to sell
                     at all. At a January  1986 national conference  on. ask
                     ci Hiiiinimration  (covspoiisored by the Conservation"
                     Foundation, the National Science Foundation, the
•Explaining Eovjraoneoul Risk Some.Neief oo EavinuKoul Riik Conummcuiaa.'  by Peur M. Sandnua for the TSCA Auuuace
Office. Office of Toxic Subnuces. U.S. Eovaoamenul Pmecuon 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 eommunicBtion should
                      be rational alertness, not passive trust.
                        If • public that views risk with rational alertness strikes
                      you as • 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
                      undemanding to design your own strategies.
                        Though I hate to admit it. risk communication is a simpler
                      fin|«i iggji dak Assessment at risk manaMmenL It just- isn't
                      that hard to understand how journalists and nontechnical.
                      publics think about risk. But it » 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, I 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
                                         job *t"»* can 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
                        iiblic Information people will find some value in what I
                         e to say. my main goal is for environmental protection
                         imissionen 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'a 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 fair part of their work.
                      Most risk managers. 1 suspect, spend a good deal of time
                      hoping the media and the public will 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 are likely to react to what
                      you have to say. and what you might  want to say differently
                            me. I hope "Explaining Environmental Risk" will  help.
       I Eaviroaineaul Risk Some Notti oa Eavnoumul Risk Commnniniion.' by Pact M. Sudan for the TSCA Auiiuocr
Office. Office of To*ic Snteuocex. \JJS. Eavnoameaul Proteoioo Agency. November 1986.

                        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. Mayrae Jorkat. 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 Lanaid and
                      Emilie Schmeidler), funded by the Fund for New Jersey; (3)
                      "Manual and Conference for DEP Risk Communication" (with
                      Caron Chess and B.). 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
                      Conncif 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, N/. 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 Slates 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.
'Explaining Envfeoanunul Rub Some Nous on Environment*! Ruk Communication/ by Pew M. Sandman for the TSCA Asmum*
Office. Office of Tone Substances. U.S. Environmental Pmeeuoo Agency. November 1986.

                      Dealing With The  Media
                      1. Environmental 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—the 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
                      most }mfTM>tTtT aa an academic exorcise. 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 tint 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
                      assessment,  the details of how great the risk is likely to be.
                      how sun the experts are* ox how they found ant. If the'story
                      u> important enough, tfaaee technical detail* 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 • 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
'Explaining Environmental Ride Some Now aa Environmental Risk Commmicalion.' by Peur M. Sandman for the TSCA Assistance
Office. Office of Toiic Substances, US. Environmental Protection Agency. November 1986.

                        The nature of the 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
                      effects even after they am 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 ndfl&cootaBiiulion. P*<*»«'«
                      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
                      technical debate surrounding the standard.
                        The madia's focus on the politics of risk rather than the
                      science of risk is most visible in the sources relied upon in
                      risk coverage. In* the New Jersey study. 57 percent of the
                      sources cited were government, with state government (22
                      percent) leading the pack. Industry captured 15 percent of
                      the paragraphs; individual  citizens and advocacy groups
                      were dted in 7 percent each. Uninvolved experts such as
                      academic*—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
                      environmental groups may also have 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
                      meat of journalism. Yet the public needs to understand
                      afastnctiora like the uncertainty of risk assessments, the
                      Impossibility of zero risk, the debatable usuiuptiuiis
                      underlying dose-response curves and  animal tests. Where
                      possible, it helps to embed some of these concepts in  your
                               i 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
                      ha 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 all  possible positions on an
                           i Typically, reporters give short ahrtft to 0.1.». and 10:
        Envooomeaul Risk Some Now* OB EBWMIMOUI Risk Conmmicuon.* by Pcur M. Saadmu to the TSCA Aunuocc
Office. Office of Toiic Sutmuccs. VS. E**BOUBMU| Prwecuoo 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. S. 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 lepurtiiig accurately what they had to say.
                        It does not mean filling in the uninteresting middle, and it
                        certainly does not mean figuring out who is right. Journalists
                        who insist on trying to t'igure 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 wail. Reporters
                        are busy chasing after the sources they have 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 manager 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 let 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 will 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
                        miliflfriiininfl faaiiirr on. the, pcooieois of technical prediction.
                        but it's more likelv to be a "color storv"—4he fears- of
"Explaining Envronmenu) Risk: Son* Notes OB Eavireamegul Risk Comimuicauoa.' by feus M. Saadmu. .jc the TSCA
Office. Office of Tone Subsunces. U.S. Environment^ Praecuoo Ageocy. 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
                      political content is more readily available than technical
                      content. Experienced sources work at filling the vacuum.
                        Although journalists tend not to believe in
                      Truth>with-a-capital-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
                      someone who veil. 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
                      grind 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 there
                      are other reasons for dichotomizing risk. (1) It is difficult to
                      find space for complex, nuanced. intermediate positions in a
                      typical news story, say 40 seconda on television or IS short
                      paragraphs to • newspaper. (2) Virtually everyone outside his
                      or her own field prefers simplicity to complexity, precision
                      to approximation, and certainty to tentativeness. As Senator
                      Edmund Muskie complained to an  aide when the experts
                      kept qualifying their testimony "on the other hand": "Find
                      me an expert  with one hand." (3) Most of the "bottom lines"
                     •of journalism ore dichotomies— the chemical release is either
                      legal or illegal, people either evacuate or stay, the incinerator
                      la either buUt or not built. Like risk managers, the general
                      public is usually asked to make yes-or-no decisions, and
                      journalists are not wrong to want to offer information in that
                        Reporters are accustomed to  the fact that technical sources
                      Invariably hedge, that nothing is  ever "proved." They see this
                      as a kind of slipperiness. Someone can always be found to
                      advocate a discredited position (the tobacco industry has
                      plenty of experts): no one wants  to go too far out on a limb
                      in case new evidence points in a different direction;
                      researchers in particular like to leave the issue open so they
                      can justify more research. Pinning down evasive sources is a
                      finely honed journalistic skill. In terms of our O-to-10 scale,
                      reporters spend.a,faiz amount of  time trying to. get S-ish
'ExpUiniaf Eauutmiutiiul Risk: Some Now oo Envmomenul Riik Commnaioiion.' by Peur M. <«•*•«• for ibt TSCA Auuuocr
Office. Office of Toxic Submncet. VS. Environmental Pmeouoa Agency. November 1916.

                        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 sale or absolutely dangerous*
                      "mom-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
                                your answers to irxeJevaot Questions* Leave
                      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 reported to sit 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
                      not "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.

                      5. 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
                                 "Have you stopped drinking it yourself?"
                      "Would you let your family Ite thewT Such questions fly. in
        Eavireqmeaul Rub  Sane Naa aa Eoviraamnul Riik CMamuaicMioa."  by Peur M. «••*••- far the TSCA Ai«i
                       the face of the source's technical training to keep oneself out
                       of one's research, and they confuse the evidentiary
                       requirements of policy decisions with the looser ones of
                       personal ^^m*- But for reporters. *pi^?*""»« that
                       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 EDB contamination), while lepuiters 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. It is often possible to
                       answer with both one's person! views and one's policy
                       recommendations, and then to explain Che 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.

                       8. Gains of risk are usually  more newsworthy then 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 (act. the denials
                       gat even leu 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
                       •M*M*I**"B here might be risky is thus the core of the story;
                       having covered ft. the media- give luther less attention to the
                       counterbalancing notion that it might not be risky.
"Eipliining Environmental Risk: Sooe Noia am Eovinomnul Risk COBUBUBICMIOO.* by Pewr M. Sudmia for the TSCA AUKUIWC
Office. Office of Toxic Sutananees. US. Eavaoameaul Praeeuoa Agency. November 1986.

                        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 ouch more interested in selling stones than in
                      -sailing 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*—is the media's traditional skepticism toward
                      those in authority. Most news is about powerful people, but
                      along 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
                      thu attention it mow rnniiMnnlly friendly.
                        On the other hand, the media an 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
                      first 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 technology ia pexfaapt too deeply embedded to be
                      dislodged) does the risky side of the argument catch up and
                      pull ahead. This may be the wont 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 ia 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 first 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
                      infoRHCMBF that suuKthing previously assumed to be safe
                      may or may not be hazardous naturally strikes people as
•Eipbiaiai EBvironKaul Risk Some Noes an Enwoeraenul Risk Cotntamiauon." by Paer M. Sudau far (he TSCA Asniuoce
Office. Office of Tone Subsuncei. U.S. Eavaoamtnul Pnxecuoa Agency. November 1986.

                       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* •~-i«»«gi«* Allan Mazur has found that public
                       feaifulnesa 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. Reporters do their jobs with limited expertise end lime.
                       At all but the largest media, reporters covering environmental
                       risk ace not likely to  have any special preparation for the
                       assignment. Specialized environmental reporters are more the
                       exception then the rule. 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
                       average 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 too 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 tu
                       find out enough to write the story. Even if they knew mure.
                       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
                           , the avenge reporter at a smell daily newspaper takes
                               rhaps S13.000-S18.000 a year. Considering their
        Eavmanraul Risk: Sane Naut OB EovraaeHil Risk Comnmnifiuoa.' by Peur M. Sudan for the TSCA Auinaocr
Office. Office of Tone Substances, VS. Eaviramnraul Prateaioa Ageacy. November 1986.

                       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 ail 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
                       • 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 (he PR at Chernobyl or Bhopal?
                       But inadequate communication skills can create a disaster
                       that needn't have been.
                        And adequate communication skills are not so hard 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 n.anagers. 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
                        Measure or not. the risks of ducking the media are far
                       greater than the 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 finure out how  to deal with them. By
                       improving your own performance as a source, you eon bring
                       about a real improvement  in media coverage of
                       eaviranmenUl risk.
        Eavaawneoul Riik:  Some Notet OB EaviramrauJ Risk ConuminicmoB.' by Pew M. Sudmu for the TSCA
Office. Office of Toiic Subetucei. US. Envirowneattl PraecUM Agency. November 1986.

                      Dealing With The Public
                       1. Risk perception is • 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 ««»*«?*"•«
                        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 (he
                       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 hawrlnus waste, treatment
                       farility  the fanner is familiar aad under one's own control.
                       while the latter is exotic and controlled by others.
                        Risk perception experts (especially psychologists Paul
                       Slovic. Sarah Lichtenstein. 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
                       are not distortions of risk: they an part of what we mean by
                       the term.
                      ' Risky                           Men 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 antigatiarr impassible
'Eipliiaiaf Eavmmnui Risk:  Some Now OB Eavinamenu) Riik Communication.* by Peur M. Sudnu for the T5CA Auinanrr
Office. Office of Toxic Subnuees. US. Environmental Protection Agency. November 1986.

                         The very same risk—as experts see these things—will 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
                       miifh ypi^iiar health risk. State nittrtai^ 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
                       ""**«Br< and fearful, 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 yean, 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 puttie or apathy.
                       And since these differences between risks are real and
                       relevant, it helps to pul them on the table. Merely
                       acknowledging that a risk seems especieUy fearful because it
TmUining Eavjmmeaul Riffc Seme Motet on Eavmuneoul Riik Caaauaiciiioa.* by Parr M. StadniM far the TSCA
Office. Office a* Toxic Subnuce*. US. EavaaameauJ Protection Agency. November 1986.

                      is unfamiliar or unfair will 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 could, 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 are alarming or reassuring in varying degrees.
                        Finally, people's perception of risk is greatly influenced by
                      the social 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 or '"•*''"'<«"• whose duciiitnns an putting us at risk?
                      Do our friends and neighbors consider the risks tolerable or
                      intolerable? Are 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 then risk data. The public
                      is far from sure that risk is the real issue in the first place.
                      Over the past several decades our society has reached near-
                      consensus thai me  illy wrong—not just harmful
                      or dangerous, not just worth preventing where 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 there are cheaper ways to save lives. The police do
                      not always catch child molesters. 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
                      "insult!" (another term with moral overtones) a society
                      should reject on moral grounds and which it should SIIBJI
'ExpUuiof Eavirauneoul Riik:  Some Nou» oa Eavnaamcaul Riik Coovmmiouoo.'  by Peur M. Sudauo for the TSCA Auisuncr
Office. Office of Toiic Sutanuees. US. Eavmneaul Pmecuoa 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-and-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. Just 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
                       community 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
                       ittttgn mora 'Tjmt^r1^ tKa« tha miQjQuxaiion of *>i*g^ risfc 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.
                         fn 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 gel angry, even that smoking might or
                       night 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
                       (aovannssflt. say 1 should dA IB prated **"•**  On my own
"FipUimm Eovironineoul Ride  Sam Notts am Eavmanenul Riik Caaunaiauaa." by four M. Sudmu for the TSCA Auuuoce
Office. Office of Toiic Subniaco. US. Eonroameaul Praccuoa Agency. November 1986,

                      behalf. I nay choose to tolerate a risk or to protect against it.
                      but for you to decide that my risk is tolerable is itself
                      intolerable. Quantitative risk assessments, risk-beneuM
                      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 issue* 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.
                      If the) goal is. an actively concerned  public, then 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
                      la to be done?
                        Any environmental risk controversy has two levels. The
                      substantive issue is what to do; the process issue is who
                      decides. So long as people feel disempowered on the process
                      issue, they are understandably unbending on the substantive
                      issue, IB 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. It 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. It 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
                      osdecstoodv this> relationship between suhsouitivtt- *m*t^ ITVJ
                      the process issues of equity and  control. Consider  for
•EipUiaing EroroameDUl Risk Some Nou* on Environment] Riik Coaununieuon.* by Pear Ml Swdau far the TSCA
OBiee. Office of Tosic Sabsuace*. VS. Envaaunul Protection Agency. November 1916.

                     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, franticwry €01)001109 onnntnition on the
                     unacceplability 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
                     •ito developer, they become <|uit0 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
                     lean for • reason  either we're Curious, or we've committed
                     to • point of view eno Moving' for eRinronrtion. 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 piupeily considered.
                     (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 learn 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  rale 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
                     ojesnrtv our*. resvrvBtionsz if tnv crisv • nrejent enQusjh we*
'EipUiaiBf Eavooameaul Riik Seme Sou* oa Envtraomeau] Risk Coonuiotioo.* by Pewr M. Sudnwa for the TSCA Auiiunct
Office. Office of Tone Sabmacei. U.S. Eavmmeaul Pmecuoa Agency. 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 when, citizens determine that
                       the issue is important, that the authorities cannot be trusted.
                       and that they themselves are powerless. Then comes the
                       backlash of outrage.

                       9. Risk decisions are better when the public shares the
                       power. People learn more and assess what  they learn 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.1
                       Interestingly, corporate officials may sometimes find
                       power-sharing lea* 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
                       better f**u  P"* mirt public- paTtiripatHtn is> too little too later:
                       "After yean of effort, summarized in this* 300-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 tit the. process and continue throughout  This
                       means an agency must be willing to tell the public about a
                       risk be/ore it has done its homework— before the experts
                       have 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
                       made into  an asset, a demonstration of real openness to
                       public input The goal, after all. is to enlist the rationality of
                          f*4friveutw aMi fthafl
                              lv figonoathow greet the risk iaaad what to do
                      about it
"Fipliining Eavramnul Risk: Sane Ncui aa Eoviraunenul Risk Cbmimmicuiaa." by Peur M. Sudan far the TSCA
Office. Office of Toxic Sutauncei. US. Emrraamul Proceeuoa 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 are 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 is 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 Tola of Two Gties had no trouble with Hot
fioorf far BOW complex 0130001019 on now lo ad)uji one •
sparkplugs for a fast start on t 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
{argon 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, jargon 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 ovoid 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
                        , nothing, much is
                            ejn> expert even when, nothing, much is at tlahit When- a-
                       potenbefly serious- risk is at stake.
-Eiphiaiai Eovramenul Riifc Some Naa oo Enwonmeaul Rut rnrnmrniinimc.' by taer M. Sudraa for the TSCA Animate
Office. Office of Toiic Sutauacw. US. Eavmnmenul Prauoion 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 hatiH effective **«y«tTim«
                       merits are intrinsically complex and uncertain, but also
                       because audiences cling tenaciously to their safe-or-
                       dangerous dichotomy. One path out of dichotomous
                       thinking is the tradeoff: especially risk benefit, but also
                       risk-cost or risk-risk. But there is, 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 any risk comparison that
                       ignores the distinctions listed at the start of this section.
                        The ft**i option to dichotomy is to provide, ihn tt/*t*nl date
                       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 iimlenland Those who are frightened, angry. *Bd
                       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 dp with fear.
                       anger, powerlessness. optimism and overconfidence than
                       with finding ways to simplify complex information.

                       7. Risk communication  ia easier when emotions are seen aa
                       legitimate  It follows from what we have been saying that an
                       iinpoitairt 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
                       confident that the nak ia small and. **** facility needed, may
        Eavjmwneaul Riifc  Sow Note* on Eavmoneoul Riik Coamuiaiiaa.* by Pcur M. <-~«—•« for the TSCA
Office, Office at Toiic Submnce*. US. EavirmneBUl Protection Agency. November 1986.

                       well try to sympathize with the target community—but their
                       training tells them playing the odds is a good bet. somebody
                       has> to take, thg risk, *h«» dM-iai^n is rational, »nr\ that's the
                       end of *h* nutter.
                         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 feeling) before trying to explain anything substantive—
                       because any effort to explain substance first 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. "I
                       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 I would be angry about this" are even more
                       empaihic remans. legitimating' the anger without labeling the*

                       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
                       cairn working environment and the trust and respect of the
                       community. Instead they are at the center of a  maelstrom of
                       •^immunity distrust, perhaps even community hatred. It
        Eovooaneaul Riifc Same Nota OB Eavmameoul Risk ConummiaiioB." by Peur M. Sudmu for itae TSCA ASSIIUIKC
Office. Office of Toiic Subauce*. VS. Eavaoamenul Protection Agency. November 1986.

                         The pain can easily transform into a kind of icy paternal-
                       ism, an "I'm-going-to-help-you-even-if-you-don't-know-what'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 control 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, tnmai control oft^1** "i*'"iay» ri«-icinti 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
                       Riftfe" is that risk MP*i^^tjindiDti and risk dflcisioD*inAki&fl
                       will improve when control is democratized. We will know
                       this is happening when citizens begin approaching risk
                       Issues more coolly, and experts more warmly.
"Eiplainiog Environmental Risk: Some Nous on Environment*! Risk Commumciuon." by Peter M. Sudmin far the TSCA A»i
                     Selected Bibliography
                        Covello. Vincent T.. "The Perception of Technological
                      Risks: A Literature Review." Technological Forecasting and
                      Social Change, 1983. pp. 285-287.

                        Cbvello. Vincent T.. Oetlof von WInterfeldt. and 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. 1986). In press.

                        Fischhoff, Baruch, "Protocols for Environmental Reporting:
                      What to Ask tha Experts." The Journalist (Foundation for
                              i Commanications). Winter 1985. 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.

                        Mazur. 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).

                        PreBioemrs Commission on tne Accident at Three' Mile
                      Island. Report of the Public's Right to  In/ormation Task Force
                      (Washington. DC: US. Government Printing Office. 1979).

                        Ruckelshaus. William. "Risk in a Free Society." Risk
                      Analysis. September 1984. pp. 157-183.

                        Sfndrmn. Peter M.. "Getting to Maybe: Some
                      Communications Aspects of Hazardous Waste Facility
                      Siting," Seton Hall Legislative Journal. Spring 1986.
'EipUiniag Eavjroaneoul Riifc Some Naa oo Eaviraenieaul Riik Canumiaiaiioa." by Pact M. Sudmu for the TSCA Auisuncr
Office. Office of Toxic Sutouocci. U.S. Eavmaneaul Proicaioa Agency. November 1986.

                        Sandman, Peter M.. David B. Sachsman, Michael
                      Greenberg. Mayme Jurkat. Audrey R. Gotsch, and Michael
                      Gochfeld. "Environmenul Risk Reporting in New Jersey
                      Newspapers." Envmuunenta) 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
                      Risk," pa«M«i««i p««i»q>?h Report 85*5. November 1QA4.

                        Slovic. Paul. Baruch Fischhoff. and Sarah Lichtenstein.
                      "Facts and Fears: Understanding Perceived Risk." in R.C.
                      Schwing and W. Al Aibers. eds., Societal Risk Assessment:
                      How Safe It Safe Enough? (New York: Plenum, 1980). pp.
                        Weinstein, Neil D.. and Peter M. Sandman,
                      "Racommendatiora for a Radon Risk Communicatioa
                      Hugmn. OBtce or SCMBCV stiff RSSBBCII. New Jersey
                      Department of Environmental Protection. November 1985.
'Eipbining Enviroameoul Risk: Some Notti oo Eoviraameaial Riik Commuucaboo." by Peter M. Sudmu far ihr TSCA
Office, Office of Tone Subnuces. U^. Eavmaneoul Prelection Agency. November 1986.


                         PUBLIC MEETING


                              Prepared by

     CDR AMn Chun, USPHS, Senior EnylronmenUl Health Policy Advisor
                   Arnold R. Den, Senior Sdence Advisor
                    Office of the Regional Administrator v
               U.S, Environmental Protection Agency, Region 9
      Following is a list of questions which, are 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.
• Cardinal Rule 92 from EPA's S*vcn Cardinal Rula of Risk Communication (See ptgel)


    Seven Cardinal  Rules  of  Risk Communication
        1. Accept and involve the public as a legitimate partner.
        2. Flan carefully and evaluate your performance. (CK23
        3. Listen to the public's feelings. (CR3)

           (Examples of "active listening1 are offered in some of the
           responses to the questions which follow. These specific
           examples are imderKngd 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)
•Poblic Meeting: Typical Questions ud Sample Responses.' By Alvin Oiun tad Anold R. Den. Office of the Region*! Admiauiru.*
Office of (he Senior Science Advisor. EPA Region 9. revised Juuwy 1991

      L     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 Note; Underlined sentences are PfffrPTlgs of nacfjyc listening."

            A.    Sounds like there 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.) (OU,3)

            A.    I know you *U have a lot of Questions that vou 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: Listen, feedback with a
                  recommendation  and accept the public as a legitimate partner in
                  deciding on the agenda.) (CR1,3)

            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 faith hand nosed 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.     QL    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 your questions. I have
                  written your questions here ton flip chart), and I have saved this
                  part of 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 ud Simple Responses.* By Alvto Chuo and Arnold R. Den. Office of the Regional Administrator
Office of (he Senior Science Advisor. EPA Region 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 well have to think of something else.
        (Principles: Listen, feedback with helpful suggestions and
        involve the public in deciding how to proceed.)  (CR 1/3)

  A.    You've asked a very good question and maybe we haven't been
        listening too welL How many of you have Questions and would
        like them answered? I see there 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, ftmimayiyac 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 aD 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 let*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?

  A.    Poor Response:  Sir, if you would just let me finish, 111 get to
        your question at the end, and we'll answer all questions then.
        (Not listening to the publiq 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
        been a-good response. However; this is usually not our nrtpndfid.
        goaL Our goal normally is-to try to meet the needs of the

•Public Meeting: Typical QoeAtoas and Subtle Releases." By AJvin Own tad AnoU R. DM. Office of the Regional Adminutruor
Office of Ac Senior Science Advinr, EPA Region 9. revised Jaeuwy 1991

            community in trying to solve the environmental problem.
            Given mat 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, and. if we care.

      A.    Sir, vou'd like to know what we're doiny. and you're angry 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: T have 5 other sites that I'm working on and I'm
            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.)

L     Q    Why haven't you closed the plant? How many more cancers do
            yon want?

      Underlying  Public Need:  The public is  worried about cancer (or some
      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  t'"'rM^'ng some immediate actions which will ensure
            yuur safety. Here s what we are proposing and we believe this

 "Public Meeting: Typical Quemou and Sample Reipoua.' By AJvio Qiuo ud Anold R. Den. Office of the Regional Adnunuirai.*
 Office of the Seoior Science Adviser. EPA Region 9. revued January 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 if s necessary!

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

      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  "micro1' 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. 10~5 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 Electrobotics because DNC isn't in the
            air or drinking water.  For residents to the west of Electrobotics,
            DNC is only preset ia the air, bat in such small quantities mat
            exposure will only be a health concern if it is not reduced in the
            next several years. 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 cannot 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 Electrobotics because it isn't in the air
            or drinking water. For residents to the west of Electrobotics,
            DNC is only present in thp air, but.iii.such *»»»*ii qna«»i*iac that
            exposure wuZ only OB a health concern IT it is not reduced, in the
            next several years. We are proposing immediate actions to

'Public Merlins: Typical Question! and Staple Response*.* By Alvia Qua ud Arnold R. Oca. Office of the Regional Adnuoutrauw
Office of (he Senior Science Advisor. EPA Region 9. revised luury 1991

          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"* to 1(H> 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 10~*.  Based on that estimate,
          we feel that we should reduce the risk to a level of 1(H>. (What's
          probably not needed here is more jargon.)

    QL    Are there any safe Icrrfy for a cmuiugeii? (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 will 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 ^ri**M moan- ftyostaiprife tfr^t 10*^ OT 10"^ risk. IS a Safe
          leveL There are uuiiy msons why zmo risk my not be feasible,

'Public Meeiiag: Typical Questions tad Sample Responses.* By AJvio Qiua and Arnold R. Dea. Office of the Regional Adimni>i:.u «
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 are, 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.  1 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 ttvCTft is no immediate ^ayar^ *«H we fT1 H0*^ up 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 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 mat  Our goal is to make it as safe as possible
             with your input I believe we can develop  a solution to control
             the risk.  (CR3,4,7)
       A.    Poor Response:  It's acceptable because the risk is 1(H». 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 I 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 1 X 10 * 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, \jt., "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
       willing to focus on the 10^ 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  10~6 will not  be needed! Often
       times agencies  tend to focus on  the 1(H> issues  too soon with the public
       without  adequately addressing the  real public concerns.  This then
       creates a diversion to argue about 10* and misleads the agency  to
       tkhtk that if anfy they could, have explained 10* better,  it would hoot
       not created an argument with the public.  The argument was probably
     Meeting: Typical QUCJUOM and Simple Response*." By AJvio Chun tad Arnold R. Den. Office of (he Regional Adimnwrai.*
Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

       over the agency not listening, and as • 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.  1 x 10 "^ is
             another  way of saying one-in-a-million chance of getting cancer
             (above the nonnal background **ar>*fT?)- In. our definition* oner
             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  die absence of sufficient data.
             worst case and txpperbound »*«»iiiipti«fif are used m the 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.) (CR 3,4)

       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"6" 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
             •'iniifi^jH^Ba  However, we say VWPSH cancer risk" and.
             "additional cancer" because we already expect to see, due to an

"Public Meeting: Typical Quemoai Md Simple Rripnoici.' By Alvio duo aad Anold R. Deo. Office  of the Regional Admioiiiraiur
Office of (he Senior Science Advuoi. EPA Regie* 9. revued Juuary 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 me 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 be

         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 heranse we have reasons to believe mat 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 if s sale in the short term, but on the other hand we're
               proposing to dean 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  dearer. 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 are safe because die cable hasn't
               snapped and it isn't likely to.  You may feel safe for a long time

•Public Meeting: Typical Qaenoni ud Sample Response!.- By Alvio Chun tod Arnold R. Den. Office of (he Regional Adminiiuu.*
Office of the Senior Science Advisor. EPA Region 9. revised January 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 unaffnnfabte  Then
            youll 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
            DNC in the air.  In that situation, the the weight of the cement
            or DNC contamination is closer to 500 Ibs and our clean up plan
            calls for the cement or DNC to be reduced to less than 5 Ib. Even
            with, 500 Ibs of r**n°y** there is still, some *****n ^ViaTn^o 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 KT6 is, I hope it gives you a better idea of how
            small 10** risk is, and why we are proposing these actions.
       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
             rentable explanation or example, it will be non-productive and
             create outrage.)

 10.   Q   Am I the one-in-a-million?  Why isn't it zero?

       Underlying Public Need:  The public is concerned about how 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 the rjgfc numbers would affect von
             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 situations to be on the safe side. The assumed
             exposure sxttulions are veiy nnnTcply, but because' or the
             uncertainties  about cancer, we wanted to be as protective as we
             could be. As a consequence, the actions we will take to reduce
             your risk based on these assumptions will be more substantial or
             health  protective than if we had assumed more typical exposure
             situations.  For example, we assumed a maximum exposure to
             DNC of 24 hours/day, 365 days/year for the next 70 years. • If this
             describes your current situation, you may have at most a one-in-
             a-million chance of getting cancer from DNC  If you are exposed
             to DNC for less than 24 hours/day, then your risk is even less.
             Conversely, under those extreme exposures you have at least a
             999,999 in-a-million  chance of not getting cancer from DNC, and
             an even much less chance if your exposure is less than the
             extreme situation we assumed. In your case, I would guess that
             you will not be constantly exposed to DNC for all of your life,
             and thus your chance of getting cancer from DNC is much less
             than one-in-a-million, and for all practical purposes is zero,
             especially when one considers all the other health protective
             assumptions that are used. (CR3,4>77

"Public Meeting: Typical Questions aad Sample Responses." By AJvin Chun ud Arnold R. Den. Office at the Regional Administrator
Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

      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.

1L    Q.    What does 1 ppb mean; 1 iig/1; 1 ng/m3?

            CHie context of this question is that we've been using I 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,

      A.    Fm somr 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.

      A.    1 ppb is a term Cor. 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 that dear up the confusion? (CR 3,4,7)

      A.    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
"Public Meeting: Typical Questions and Sample Responses.* By Alvin Quin and Arnold R. Den. Office of the Regional Administrate
Office of (he Senior Science Advisor. EPA Region 9. revised January 1991

   12.    Q.    What does RCRA mean?

         A.    See Answers to Question* nil. (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, and 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. eoetyUiing 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 witntcd 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 resources to deal with these, problems.) However, we
              are taking axtluns to solve the prouiemv and here's wlui we are
              doing to protect your health: ------------------------- (CR 3, 4, 7)

'Public Meeting: Typical QUUUOM tod Sample Reapmie*.' By Alma Chun tod Arnold R. Dea. Office of the Regional Adminisirai.*
Office of the Senior Science Advuor. EPA Region 9. revised January 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.

 15.    Q.    What does 0.07 deaths mean? How-can you have a partial

       Underlying Public Need:  The public is confused  by the information
       and would like clarification so that  they can better understand it.

             (A suggestion here is to revise die 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.)

       A.    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)

       A.    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
             this question.)

       A.    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 frank and say so.  You  may have to repeat this
       several times, but never fuess or make uo an answer  because vou feel
       pressured: this is a sure toav of losinf anv trust and credibility vou mav
       have  established.

       A.    I'm 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 for you. May I see you after this meeting and get
             your phone number? (CR 3,4,7)

*Public Meeting: Typical Qncnieai ud Simple Rcfpoua.* By Alvia Chun ud Anold R. Den. Office of the Regional Adnunisirau*
Office of fee Senior Science Advisor. EPA Region 9. leviied 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 now ready  to consider solving the problem.  They also realize
      that EPA can't  do all they had initially expected.

      A.    I share your concerns  about the value of your 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
            concern 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 Tm 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
            consult with other credible sources when it is nmted)
  •Public Mecuog: Typical Questions and Simple Response*.' By Alvig Chun and Arnold R. Deo. Office of the Regional Adnuniiuu
  Office of (be Senior Science Advisor. EPA Region 9. revised January 1992.

 18.    Q.    IVe been working here for 15 yean 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 are.  (This person's question may also represent some
       initial denial  of the risk at hand, or a concern about their job.)

       A.    Sir. Fm 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
             everyone in 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, case*, it creates unnecessary or false ***nfom^}
•Public Meeting: Typical Queiuoni ud Sample Response*.* By Alvin OMB ud Arnold R. Deo. Office of the Regional Adminuirai.*
Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

  19.   Q.    One of our very close friend* who lived near the hazardous
              waste site just died from cancer.  (Person breaks down en 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.    (On? listens snot allows the rndxvxdtzai to vent emotions, and
              empathically responds:)

              I'm sorry for your loss.  If you would like, we could discuss this
              some more after the meeting. (Principle: Listen and respond
              with compassion.)  (CR3, 4, 7)

        A.    (One listens and allows the individual to vent emotions before
              empathically responding:)
              This is an especially sad and difficult Hrpe 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 that 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) _

'Public Meeting: Typical Qaemou ud Sample Response*.* By Alvin Chun tod Arnold R. Deo. Office of the Regional Administrator
Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

       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/FS, 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 daily activities. Specifically, far 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!
             I*ve got my life savings tied up ra my home! Would you 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, \jt.. Art you, as the Agency representative, doing as  much
       for the. neighborhood as you, would if you  were a  resident?

       A.    Sir, it sounds like you'd like to know if I would buy 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?
           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 affect piopcty 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 decision. I know that if I were Irving 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.    This whole situation has not been an easy or pleasant one for
           you, and we're also very concerned. As to whether I would live
           or buy a  home here, that's usually a very complex question for
           most situations.  But if my only considerations for making 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. Total'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
           ffiif mponsibiliiiy>  Cm> SQLTY we cannot help YOU.
•Pttblk Mectiog: Typical Qiemoai tad Sample Ropoasa.' By Alvia OHIO ind Araold R. Den. Office of the Regional Admuiiuiiar
Office of (he Senior Science Advinr. EPA Region 9. nvued January 1991

21.*  Q.    I am considering buying some property here. Given all that has
            happened, would you buy or recommend buying property here
            now or 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 fm 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. Sorry, but we don't make those types of
            recommendations. (Even  though this 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 was not only honest, but it also
            offered information  that was helpful.)

            *Mvd* Mwpbv. GBWtttthar
             Olid. Public Pirtdpttfon
             California Dmimait of Twdc SubMancn* Cental
'Public Meeting: Typical Questions and Sample Responses." By Alvio Own and Arnold R. Den. Office of (he Regional Adminiftui.*
Office of the Senior Science Advisor. EPA Region 9. revised January 1992.

                  Environmental Communication Research Program
                  A program of the Agricultural Experiment Station
     Cook College • 122 Ryders Lane • New Brunswick • New Jersey 08903 • 201/932-8795

      Decisions about when to release information depend, in large part, on the
situation. However, agencies should seriously mmtn* the implications of. holding onto
Information. The next 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.

4.    You can better control the accuracy of Information if you are the.flrst to present

5.    There Is more likely to be time for meaningful public Involvement In decision-
      making if the Information is released promptly.

6.    Prompt release of information about one situation may prevent similar situ-
      ations 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-
     • matlon earlier.

10.    People are more likely to overestimate the risk If you hold onto information.
 From C.  Chess, Hance, B.J.. and Sandman,. P.M., "Improving Dialogue With
 Communities:  A Short Guide For Government Risk/Communication," (Trenton. NJ,
 Division of Science and Research,  NJ Department of Environmental Protection,


                      FOCUS GROUP TSCHHIQOB
     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-

     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-
sion 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-

     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 firm 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 qualititative 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 UL

     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 ArJcin and David McCallum.   As adapted  and
reprinted in the Risk Communication Student  Manual, edited by
Erin Donovan,  Vincent Covello and John SlavicJc (Chemical
Manufacturers  Association, Washington, DC 1989).                     145

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 "general
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 Title III 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 any 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 dose 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  a*ll  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.

   •  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
      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

   •  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, dear 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 need to read
      and a bsncfii 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 are;
      •  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 Anatvtu. ko/. i \a 4. 19/98
   .esi Editorial
Focus  Groups and Risk Communication:
The  "Science"  of Listening  to Data

William H. Desvousges1 and V. Kerry Smith2

    Focus groups are old hat in market research.
These small group discussions are commonly used to
help companies learn how consumers feel about vari-
ous products or services and to develop survey ques-
uuutMtires. Researchers interested in understanding
now people respond  to environmental risks  have
    illy begun using focus groups because they offer
    its into how people process information or an-
»w«r questions.
    Focus groups can a*€rt make 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 Tint 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 rnmmnnictit'>|B 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

'Senior Economist. Research Triangle Institute. P.O. Bos  12194.
 Research Triangle Park. North Carolina 27709.
1 University Diiunguuoed Professor. North r*r?lini Suie Univer-
 sity. Raleigh. North Carolina 2769S.
focus  groups  can make risk communication more
effective. We  also  oifer 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
communication.  .

    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, the group are relatively small. The ideal
group sue 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 decision.
    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 care 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 seiec-
                                                            U2T2-4J11/U/I20MM7VS06J10/I tl«M Soonv (or Ruk

                                                                                  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 nsks 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  """""vniration.  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 risk^ommunication mi'ypa^T
    *  Selecting ritk'KXMFlttt">l'<*at'H>> rhann»l«
    •  Designing risk-mitigation policies.
    •  Assessing iii^-f^tmTr"tn''~*t'f™i effectiveness.
3.1. Exploring Risk Perceptions

    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 '""yy are aswciatfd  with
rusted barrels of gh«™«eai«  or empty houses from the
well-publicized experiences at communities such  asi
Tunes Beach.  Love CanaL or Woburn.  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 takes a very long
    We also found that people had difficulty relating
government regulations to risks from hazardous waste
exposure. Over the course of  several vasions.  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  also highlighted differences  be-
tween technical risk  assessments and people's risk
perceptions. Some trrhniriani argued  thai, if people
only understood that  the probabilities of dying from
exposure to ha*»*dom wastes are much ••••M** than
the probabilities of dying from an automobile acci-
dent.  *h**i we could  communicate  risk  more effec-
tively. They placed primary (if not complete) weight!
on the importance of  the magnitude of the probabil- >
iiy 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 how
these  factors influence individuals' responses to risk
will require more systematic research.
    Focus groups •!««* permit evaluations of visual
aids (e.£, scales or formats) for eliciting  risk percep-
tions. Within  these group sessions,  the  analyst can
observe directly how people use a scale or how the
group  ititfflwyt their reactions, after  the scale has
been presented.
                                                     3.2. Evaluating Perceptual Cues
                                                          Focus groups are a convenient setting for ex-
                                                     ploring an array of perceptual cues related to how

Focus Groups and Risk Communication
     ie interpret and use risk information. Bv using a  i
sequence of several sessions with progressive modifi-  i
caung materials,  we found that some people pre-  i
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 10 include
both fractions  and  percentages to  explain nsk to-
gether with the nsk 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, cr both in evaluating
the risk information.
    i»mesnitg Risk-Coamunicadoa Materials
    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-
     They wanted more coverage of the lower risks
                                                                •At IM M HOI MT «•».

                                                                Fit, L Final version of the ruk ladder.
                                                      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
                                                      levels 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

                                                                                 Desvousges and Smith
 would noi 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.) Clearly, 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 muted
 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-Commuaicaooa Channels

     Focus groups are useful in selecting the poten-
 tial channels to be  used  for  co1"ti'Mt'nff  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 "T"**** 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 co*1***1"1"******1** chan-
nels and adapting the message  to meet the specific
needs of each channel— two basic tenets of  the risk-
communication literature.
    Designing Risk-Mitigarion Polities
    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 effecuveness. 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.
    There  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 effecuveness.
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 recognize that eval-
uation provides one area where focus groups may be

    To help others  learn  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 confirmauon  letter  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
       nonexpen in the nsk area. Having people ask
       the 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 role. This allows for more flexibil-
       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 organizauonal 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 teacher
       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 hoilrs. While a break
        is  generally unnecessary, a  short one can
        sometimes  help reorient  the  discussion  if
        people are tending to pursue extraneous mat-
        ters 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 tor discussion
        can alter impacts and ease anxieties.

     These ideas are based solely on our experiences
and not the result of a systematic, formal evaluation.
I'uiiciheless. they are generally consistent with the
principle: found in marketing applications.

     Our experience suggests  that focus groups can
be valuable tools in making nsk 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 nsk communication and related stud-
ies. As more and varied objectives are tried, we will
learn more about what works and what does not in
"?tnnninicanng risks. We may »!«*» 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

                                                                                    Desvousga and Smith
insights. Clearly, there is a need for more research
findings on how 10 organize and conduct the groups.
     Although focus groups can oe a valuable nsk-
comraunicauon  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 10
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
wul send you one.  Or you may simply send us your comments.  Either way, we
thank you for your feedback.
      Copyright © 1989 by Caron Chess, Bfllie Jo Hanee, 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

        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 can apply guidelines introduced
 in the  manual and short guide. While the
 manual suggests why two-way commumca-
 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 stafil 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
hinges 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 fch^> Envirf>niTH>nfcgl  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 can 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 tim«KM«- 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 thinlc 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-
ple, NJDEP's Bureau of Water Quality
Standards 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
communication planning.

   Experience suggests that some of the best
             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 Your 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 ail 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 the 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

   The purpose of this checklist is to help you
  ink  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.

_____  To answer questions that have arisen and respond to concerns in the community.

	  Other	,	

Organizational Goals
	  lb build and maintain the credibility of the agency in the minds of all affected publics.
____  lb coordinate actions within the agency and with other agencies so the governmental
       response is consistent and effective.
^___  lb »»i«rintai« 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
       lb involve affected parties as early as possible. (See checklist of potential audiences in
       Chapter V.)
       lb provide maximum opportunities for public input, including where appropriate a chance
       to help make and carry out key decisions.
       lb 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.
       lb make only promises that can be kept, and to keep the promises that are made.
       lb build a relationship with the community that is personal as well as bureaucratic, that
       incorporates feelings as well as data.


   The best way to reduce major problems in        Below are some of the areas that may pose
 a communication effort is to anticipate them     obstacles and some potential ways to over-
 and find ways to avoid them. In general, it is     come them. They are not meant to be all-
 far easier to plan for a problem than to con-     inclusive but rather to trigger your thinking.
 front it as an emergency that can derail your     Check the  problem, then the solutions you
              effort.                          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.

Potential solutions

___  Plan more rather than 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
 	__  Plan communication efforts early so they r?n be integrated into agency timelines. (For
       example, it is easier to involve the public in decision-making if the involvement happens
       •as part of rathpr 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
       materinla 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 clear with your audiences from the outset about your legal constraints.
Management Support
   The 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.
	  Failure to allocate sufficient resources.
	  Lip service to communication that is not accompanied by a commitment to recruit, train,
       and reward staff for communication skill.
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 aim 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."

   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-malting 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 following 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.
 L 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     for this particular program. Put a "2" next to
thinking rather than to be exhaustive. As you     audiences of lesser priority. Use the lines on
go through the list, it may help to put a "1"     the right to fill in names.
next to those audiences that are top priorities


___  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 co*** ™ Minna
       Emergency responders.

Geographical Neighbors

	  Local residents	
       Local businesses


_____ National groups.
      State-wide groups.

      Local groups	

       Groups related to specific issues:
       _L_ Siting	
           Hiking  .
       	Natural features (e.g. swamps, lakes, oceans,
           forests, etc.)	
       __ Gardens    •
       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
       opinion: ^^^^^^^^^^^^^^^^^^^^__^^_____«___^___^^^^_
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	

       ,^__ Sanitarians
       ___ Water purveyors
       _ Planners	
      __ Chambers of Commerce.
      	Industrial groups	
       Other trade-related:.
Educational and Academic Organizations
	 Colleges	•
      Agricultural extension.
      Public and private schools

Religious Organizations
Other Organizations


  .Unless you have a great deal of familiarity
with the issue and the audiences involved,
yOU Mn create' miaiindaratflndinga by aSSUm-
ing 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 f*nal
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 numberv 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
Program.)            •           .
   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.)
       Date: _	

       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.)
       Date:      -	

       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.)
       Date:	'

       Send a letter to potentially interested people and organizations asking them to send you a
       list of their questions and concerns. *
       (This can 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 forihe 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 communicating with.)
Date:	_^	

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.)

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.)
Date:       '

Other.____	,	

Date:          •	

   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?


 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?
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 are 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 be 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 list 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-
   taon-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-
   ten communication.)

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
 	  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
 	  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
Person-to-Person Approaches
       	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     battle, their only hope being to "come out
meeting with the public that is based on past    - alive."  While the following checklists cannot
experiences with angry and frustrated com-     shield you from communities' understandable
munity members at large public meetings.     anger over certain  situations, they can help
There is a general sense that a meeting with     you (a) do some thinking beforehand about
the public is an "anything goes" situation,     why a community may react a certain way;
and that  agency representatives can never     (b) see yourself and your agency from the
know what is going to happen until they're in     community perspective; (c) avoid angering
the meeting.                                the community unnecessarily; and (d) pre-
   As .a result of these experiences, agency     *m to resP°nd to Public Action.
people very often brace themselves for the

   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 raHia attention has the issue
   received locally, regionally, and nationally?
   Are there likely to  be reporters present at
   this 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:

_____  controversial




	  apathetic, uninterested


	  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 audience(s) 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,
       "Planning 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 tune—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, rhnlk, 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?

   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.


   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.
   Tb 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 communication 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.  Like 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 PoUing/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)
       Other tools
When will you use each tool?
Message Pretesting

___  L  Rightwxiter (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
       examine an audience's attitudes and opinions)
	  6.  Theater Tasting (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

___  L 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
___  L 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
effort 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-
resentative fanners, etc.), and when it will
take each of these preliminary steps. Because
the agency used a timeline, the meeting with
fanners 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 overcommitted 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,
   tile 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 «•-«« 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 timoimo 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 teflw out the
principal t.Vir*>nHa  In SUCh Cases,
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 like. 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 can 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 Programs1
A Catalogue of "Quick and Easy" Feedback Methods

Mark Kline, Caron Chess, and Peter M. Sandman
     Agencies that 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 shoujd 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 Dcparunant of Environ-
mental Protection. September 22,1989, by the Environmental Communication Research
Program, New Jersey Agricultural Experimental Station, Cook College, Rutgers Univer-
sity, 122RydcrsLane,NewBrunswick,Ncw Jersey 08903; this paper summarizes the full

                                        Evaluating Risk Communication Programs

Strengths and Limitations of Quick and Easy Evaluation
      In its most general sense, the term "evaluation" refers to a process of interpreting and
judging events, a process thai human beings engage in much of the time. Evaluation ranges
along a continuum, from informal, subjective imprcssionsatonc end, to formal.sciemifically
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 call them "quick and easy" methods. 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 impactevaluation 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 repealing 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 better 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 arc 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 (hat 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 inputfrom the public.butalso for using it and showing that they used it. If audiences
sense that their time 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 lend 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 subvened by this son 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 tempted 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 values and climate of an agency can have great impact on 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:

         Are 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 to 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.
      Il 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 Scicnccand 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 evaluation 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 analysis 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 comm unication effort. These strategics arc common in public relations and advertising
practice, where ongoing feedback from an audience  is important to respond to changes

2A. Conceptual/Organizing 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-1.  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 thai 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
support, or be neutral toward a decision. This tool guides the agency's internal assessment
of relevant stakeholders and involves no formal data collection. 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.

  2/1-2.  Audience Analysis Matrices
      Purpose:                  To identify relevant audiences and organize agency
                                 perceptions of their reactions, involvement, or posi-
                                 tion in a communication effort.
      Lead Time:                Low
      Staff Time:                Brief
      Budget:                    Low

        Matrices 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 audicnccs'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 10 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 too much lead time for a crisis 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 information about 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.

 25-3. 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 formal a 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 S2000. 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 Tail to convey the
complexity of public perception.

2B-4. Public Opinion Polling!Pollstart
      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.  Pollsian software costs 598.00; Public
                                Opinion Polling, a book that guides use of the software.
                                costs S19.9S.

        Pollsian 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 stcp-by-stcp guidance on how to encode the 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.

2B-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 lake 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 they are more easily understood and communicate the intended
message more effectively.  Message pretesting 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 the National Cancer Institute
(1984,1989) to be of great value in exploring and assessing these techniques. v

3A.  Brief Appronches
        These techniques give feedback in a short amount of time.

3A-1. Righlwriter
      Purpose:                 To review  documents written on computer word-
                                processing  programs  for errors in grammar, style,
                                usage, and punctuation.
      Lead Time:               Low
      Staff Time:               Low
      Budget:                   Rightwritcr software currently costs 595.00.

      Rightwritcr 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. Righlwriter docs not "understand"  the content of the text and can give  no
feedback about tone or appropriateness. In addition, some Righlwriter 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
      Staff 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 the grade  level, the more sophistication is necessary to understand the
material. Assessment of readability, along with a knowledge of the target audience's level
of sophistication, can allow agency staff to produce materials thai 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, formal, lone, 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 Slopping 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 this approach, respondents read through a document and put slash marks where
they stop. They are then provided with a coding scheme to noute 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 Extensive 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 arc 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 oilier relevant opinions. Questionnaires may include open-ended 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 get feedback on pretest materials or to examine an
                                audience's attitudes and opinions.
      Lead Time:               Moderate
      Staff Time:               Moderate to high
      Budget:                   Low to moderate

                                        Evaluating Risk Communication Programs
        Interviewers arc stationed ata 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 using closed- ended questions may deprive the agency of richer feedback from
a more extended discussion.

3B-3. Theater Testing
      Purpose:                 To get feedback on visually presented pretest mate-
      Lead Time:               Moderate
      Staff Time:               Moderate
      Budget:                  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
      Purpose:                 To get feedback on and generate ideas about pretest
                                items. To get a "feel" for the attitudes and beliefs of
                                a target audience.
      Lead Time:               Moderate to high
      Staff Time:          .   • Moderate
      Budget:                  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 gi vean 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 ihc 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. Most of these tools arc self-assessment surveys 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-Briggs Type Indicator
      Purpose:                  To provide feedback on the communication styles of
                                agency staff.
      Lead Time:               Moderate to lengthy, due to time needed  to secure
                                services of consultant
      Staff Time:               Low
      Budget:                   Moderate

        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: Extravcrsion-Introvcrsion,  Scnsing-Intuition, 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 MBTI 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
      Purpose:                  To identify the strengths of agency staff and suggest
                                ways these strengths can be  used to communicate
                                more productively with others.
      Lead Time:               Moderate to lengthy, due to time needed  to secure
                                services of contractor.
      Staff Time:               Low
      Budget:                   Moderate.  Each Inventory form costs S3.4S; con-
                                sultation is additional.

        The Strength Deployment Invcntory(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 llicir 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 lime needed to secure
                               services of consultant
      Staff Time:               Low
      Budget:                  Moderate. Each survey form costs S5.60 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 Style 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 arc processed to yield an assessment of communication style as 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 of finding out whether wlial 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
provide strategics for getting feedback on audicnccrcaction and communicator performance.

5A.  Audience Reaction
        Audiences are asked what their reaction is to a presentation.
5A-1. Meeting Reaction Form
      Purpose:                  To get feedback about participants' reactions to a
                                public meeting.
      Lead 1'ime:               Low to moderate, depending on whether die form
                                developed by  the Environmental Communication
                                Research Program needs modification for specific
                                agency use.
      Staff Time:               Moderate—includcsprcparationof 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 fell 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 apublic participation
program run by the Bureau of Water Quality Standards and Analysis (B WQS A) 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.

5A-2. Verbal Meeting Feedback
      Purpose:                  To get direct feedback from participants at a meeting.
      Lead Time:               Low
      Staff Time:               Low
      Budget:                  Low

        Time for a 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 comment 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 panici-

                                        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.

SB.  Performance of Presentation
      These techniques provide feedback more specific to how the communicator per-
forms than how the audience reacts.

5B-1. 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, comprchcnsibility. 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 Uic

53-2. Observation and Debriefing
      Purpose:                 To get feedback on speeches and presentations.
      Lead Time:               Low to moderate—lime 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
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