United States
Environmental Protection
Agency
Office of
Public Affairs (A 107)
Washington DC 20460
Volume 13
Number 9
November 1987
I
-------
Collecting soil samples to measure possible dioxin contamination. Even though EPA is
reassessing its original dioxin cancer risk estimates, dioxin is still considered to be a highly
toxic cancer-linked compound. A modern, affluent society offers many benefits, but also
presents risks.
Environmental Risk
How is it possible to
makii decisions dealing
with environmental risks
from pesticides to air
pollution in .1 complex
society with competing
interests and viewpoints,
limited financial resources,
and a lay public that is
deeply concerned about the
risks of cancer and other
illness? EPA advocates risk
assessment and risk
management as a
decision-making approach
that can avoid stalemate and
enable the society to work
out its environmental
problems rationally and with
good residts. This issue of
JiPA /(Hirmil explores the
theory and practice of risk
assessment/risk management,
attempts to put this
problem-solving approach in
the context of today's
environmental challenges,
and includes comments from
industry and
environmentalist viewpoints
on the viability of the
approach.
This issue begins with an
interview with Lee M.
Thomas, KPA's
Administrator, providing an
overall perspective and
answering questions about
the risk assessment/risk
management approach. Then
two articles describe some of
the challenges to
environmental
decision-making today,
including a national tradition
of focusing narrowly on
separate environmental
problems, the danger of
stalemate on crucial
environmental issues, and a
divergence of public: and
scientific views on what are
the most risky environmental
problems.
Then several articles
explain the risk
assessment/risk management
decision-making approach.
They deal with its relevance
to today's environmental
needs; how it works.
generally and in specific
situations; and how it can be
improved. Included are
pieces specifically on risk
assessment; risk management,
with EPA action on the
pesticide dinoseb as an
example; and on risk
communication, a term
widely used to refer to public
discussion about
environmental risks.
Risk communication
articles include an
explanation of why this tool
is important; a piece
describing how it works; and
two "case" stories. One of
these describes how EPA is
gearing up to help the public
deal with an influx of
information about chemicals
and their environmental
impacts under Right-to-Know
provisions in recent law; the
other is on efforts to help
people make wise decisions
of their own about the risk
that radon may pose in some
homes.
Then two articles feature
the risk assessment/risk
management approach on the
firing line—one report is on
the experience of using it in
an EPA regional office, and
the other article is on
applying it to help deal with
the environmental impact of
high-tech industry in
California's Santa Clara
Valley.
The next section includes
articles by two outside
observers expressing their
views about EPA's risk
assessment/risk management
approach. One is by a
scientist from an
environmental group; the
other is by a representative
from an industrial group.
This issue's coverage of
environmental risks
concludes with an EPA
Journal Forum. In this
feature, five journalists and
three journalism professors
were asked whether they
believe recent media
coverage of environmental
issues such as the pesticide
EDO and the chemical dioxin
has served to inform or
inflame the public.
Two articles outside
this Journal theme on risk
include a feature on the
environmental potential of
the Lower Hudson River,
despite; the fact that it flows
through a big city, and a
piece on the effort to protect
Cape Cod's ground water.
The issue concludes with
two regular features—Update
and Appointments, n
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United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 13
Number 9
November 1987
c/EPA JOURNAL
Lee M. Thomas, Administrator
Jennifer Joy Wilson, Assistant Administrator for External Affairs
Linda Wilson Reed, Director. Office of Public Affairs
John Heritage, Editor
Karen Flagstad, Assistant Editor
Jack Lewis, Assistant Editor
Margherita Pryor, Assistant Editor
EPA is charged by Congress to pro-
tect the nation's land, air. and
water systems. Under a mandate ol
national environmental laws, the
agency strives to formulate and im-
plement actions which lead to a
compatible balance between hu-
man activities and the ability of
natural systems to support and
nurture life.
The FPA /ouniul is published by
the U.S. Environmental Protection
Agency. The Administrator of KPA
has determined that the publica-
tion of this periodical is necessary
in the transaction of the public
"business required by law of this
agency. Use of funds for printing
this periodical has been approved
by the Director of the Office of
Management and Budget. Views
expressed by authors do not neces-
sarily reflect EPA policy. Contribu-
tions and inquiries should be ad-
dressed to the Editor (A-107).
Waterside Mall. 401 M St.. S.W..
Washington. DC 20400. No permis-
sion necessary to reproduce con-
tents except copyrighted photos
and other materials.
Environmental
Decision-Making Today
An Interview with
Lee M. Thomas 2
The Situation:
Institutional Problems
by Terry Da vies 6
The Situation:
What The Public Believes,
How The Experts See It
by Frederick W. Allen 0
Risk Assessment:
What It Is;
How It Works
by Warner North and
Terry F. Yosie 13
Risk Management:
FIFRA and the
Dinoseb Case
by Karen Flagstad Hi
Risk Communication:
Informing Public Opinion
by Milton Russell 20
Risk Communication:
Facing Public Outrage
by Peter M. Sandman 21
Risk Communication:
Getting Ready for
'Right-to-Know '
by Charles L. Elkins 23
Risk Communication:
Getting Out the Message
about Radon
by Ann Fisher 27
On the Firing Line:
The Challenge of
Environmental Risk
in Region 8
by David \Vann 29
On the Firing Line:
Risk Management in the
Santa Clara Valley
by Nancy lanni
and Keith Hinman 32
From the Outside:
An Environmentalist's View
by Ellen Silbergeld 34
From the Outside:
An Industry View
by Robert C. Barnard 3f.
Environmental Journalism:
Inflaming or Informing?
A Forum 39
Protecting
Cape Cod's
Ground Water
by Greg Supernovich 42
The Lower Hudson:
Environmental Resource
in Megacity
by Thomas O'Keeffe 45
Update 47
Appointments 4t!
-. f:T»ifc«- i
• '
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Front Cover: Kisk. Hoiv serious (ire
(he problems in our ivaler. air. and
lund'f What should we do aboul
(hem? How should (he society
discuss and debute these issues?
Risk assessment, risk management,
and risk communicad'on are being
utilized by FPA as i( uKemnls (o
find solutions to such problems.
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-------
Environmental
Decision-Making
Today
An Interview with Lee M. Thomas
A public meeting, a frequent occurrence as EPA explains environmental problems
and policies and hears questions and views from the grass roots.
For a perspective on environmental
risks as they are being addressed by
EPA, the Journal interviewed Lee M.
Thomas, the Administrator of the
Agenc}'. The text of the interview
follows:
\-t- Why are risk assessment and risk
management important to EPA and the
nation's environmental protection
efforts?
f^ Risk assessment and risk
management give us a framework for
setting regulatory priorities and for
making decisions that cut across
different environmental program areas.
This kind of framework has become
increasingly important to EPA in recent
years for several reasons, one of which
is the considerable progress we have
made in pollution control in this
country. Fifteen years ago, it wasn't
hard to figure out where our first
priorities should be. The worst
pollution problems were all too obvious.
Now that we are moving toward final
control stages in a number of program
areas, the real priority problems and
their solutions are not so obvious.
As a practical matter, we often come
down to the question whether the final
increment of a control program is
cost-effective, given the resources
available, or whether those same
resources would be better spent on
other, more pressing environmental
problems. For example, we know that
the last five percent of pollution control
is usually the most difficult and the
most costly on a percentage basis. Is it
worth it? Risk assessment and risk
management help us answer such
pragmatic questions—and also enable us
to evaluate our regulatory efforts to
ensure that we are making the
environment safer, not just moving
pollution from one place to another.
{-i What progress has EPA made over
the last several years in actually
implementing risk assessment and risk
management approaches?
»* There's been a tremendous amount
of progress in the five years I've been
associated with EPA. Risk assessment
and risk management are becoming
institutionalized at EPA, and we're
making increased use of them nationally
and at the regional level to work
through environmental and health
issues. For example, here at
headquarters, the Agency's Risk
Assessment Council is doing important
work on science policy issues that
require coordination across programs
within EPA, and may involve other
regulatory agencies as well. The Council
works in close concert with the Risk
Assessment Forum, which reviews
specific scientific and technical issues
and refers broad science policy
questions for the Council's
consideration.
There is still much to be done—in
terms of incorporating risk assessment
and risk management concepts into all
our programs, as well as refining the
EPA JOURNAL
-------
risk assessment process and its
underlying assumptions. But overall we
have made great strides in the last five
years.
Q
In a study completed earlier this
year, EPA used risk assessment to rank
environmental problems ranging from
underground storage tanks to indoor
air pollution to global warming. The
Agency's own report from this study,
entitled Unfinished Business, points
out that the environmental issues of
greatest concern in public opinion polls
do not correlate well with EPA's
findings on relative risks. Why this
discrepancy?
^ I think EPA needs to do a better
job of getting across to the public what
we know about the risks associated with
particular environmental problems, and
how these risks compare from one
source to another. The comparative risk
report, Unfinished Business, is a step in
that direction.
We initiated the comparative risk
project to gain a systematic overview on
our environmental objectives—where
we can go from here. In the process,
it became apparent that our findings
were at variance with public perception.
It is also apparent that the public places
great weight on certain qualitative
aspects of risk, such as the degree to
which risk may be voluntary, familiar,
or equitable, that were not included in
the Agency's comparative assessment.
We need to keep such qualitative
factors in mind as we shape our
programs.
How extensively do you see
comparative risk being used for broad
management decisions such as setting
budget priorities?
'» I feel certain that comparative risk
assessment will play an increasingly
integral role in major policy-setting
decisions including budget priorities.
However, it cannot be the sole factor
considered in such decisions. With
budget priorities, for example, there are
other considerations including specific
mandates established by law. Clearly,
our budget priorities must enable us to
meet our statutory mandates, and it is
also necessary to consider such factors
as costs and available technology.
Nevertheless, in this context, I do see
comparative risk becoming more
important in the future for EPA and
other regulatory agencies.
^ The basis for risk management
decisions is defined differently in the
various statutes that EPA administers.
Is it possible to have a uniform
environmental protection policy when
such differences exist?
** First of all, 1 believe it is possible
to have a uniform policy as far as risk
assessment is concerned. You asked
about risk management. Clearly there
are differences among our statutory
mandates for making risk management
decisions. Some call for cost-benefit
analysis as a component of
decision-making. Some specifically do
not allow us to make cost analysis a part
of the decision process.
I would like to see consistency in risk
assessment fully institutionalized across
all our programs. I also think we need to
take a critical look at the consistency of
our risk management decision processes
in our different program areas to ensure
that we are as consistent as possible
under existing laws. Where we do not
have sufficient statutory flexibility to
achieve a workable consistency in risk
management decisions, it will be our
responsibility to work with Congress on
possible legislative solutions.
{-1 What do you see as the strengths
and disadvantages of the different
statutes from a risk management
standpoint?
*» In my view, those statutes which
allow us the flexibility to take into
account a broad range of factors in
making risk management decisions best
enable us to manage environmental
programs. I say this because there are a
broad range of regulatory problems to be
dealt with in this country, all of which
have resource implications. 1 believe
EPA should have the authority and
flexibility to look across the spectrum of
environmental problems and make
decisions to ensure that we are getting
the most environmental protection for
the resources we spend.
Definitions
Environmental risk assessment
may be broadly defined as a
scientific: enterprise in which facts
and assumptions are used to
estimate the potential for adverse
effects on human health or the
environment that may result from
exposures to specific pollutants in-
other toxic agents.
Risk management, as the term is
used by EPA and other regulatory
agencies, niters to a
decision-making process which
involves such considerations as
risk assessment, technological
feasibility, economic information
about exists and benefits, statutory
requirements, public concerns, and
other factors.
Risk communication is the
exchange of information about
risk.
NOVEMBER 1987
-------
LJL Doesn't the trend seem to be going
in the opposite direction, with
legislation becoming more prescriptive?
r\ In some respects, the recent
legislation lias become more
prescriptive, but not necessarily with
respect to the risk management decision
process. Consider the new Superfniul
law, for example, which was passed in
the wake of extensive debate on cleanup
standards and schedules. Congress
ultimately gave us a good deal of
flexibility so that we can take a broad
range of factors into account in
establishing cleanup standards under
the new Superiund. On the other hand.
Congress has recently given us some
very prescriptive time frames for taking
specific actions, and unfortunately this
does take away the flexibility to look
across comparative risk scenarios and
say, let's work first on controlling those
that present the greatest risk.
\j. When you look at risk, how do
you decide how safe is safe, or how
clean is clean?
A\ To begin with, you have to look at
both sides of the risk equation both the
toxicity of a pollutant and the extent of
public exposure. You need to look at
both current and potential exposure.
considering all possible exposure
pathways. In addition to human health
risks, you need to look at potential
ecological or other environmental
effects. You conduct the most
comprehensive risk assessment you can.
but there are always uncertainties, and
you must make assumptions.
From a risk management standpoint.
whether you are dealing with a
site-specific situation or a national
standard, the deciding question is
ultimately: What degree of risk is
acceptable? In general, we are not
talking about a "y.ero risk" standard, but
rather a concept of negligible risk: At
what point is there really no significant
health or environmental risk: at what
point is there an adequate safety margin
to protect public health and the
environment. In addition, some of our
environmental statutes require us to
consider benefits together with risks in
making risk management decisions.
U. Large segments of the public and
Congress seem to view environmental
protection as essentially a moral issue
with zero risk as a goal. How can risk
management take this into account?
r\ Well, in one respect, it is possible
for EPA to promote the goal of zero risk
by emphasizing preventive regulatory
policies so that pollution does not occur
in the first place. For example, we can
strive to ensure that the pesticides we
register under our pesticide program do
not have the potential to leach to
ground water.
On the other hand. 1 think your
question raises a dilemma that we face
in that it is simply not possible to
develop "x,ero risk" environmental
programs across the hoard. Certainly
public health and environmental risks
can be minimized, but I don't believe
we can eliminate all such risks. Ours is
not a risk-free society.
U Some people believe that risk
management is really just a code word
for cost-benefit analysis. They contend
that because we know how to calculate
costs better than we can project
benefits, risk management is always
going to be on the negative side of
environmental protection.
r\ Cost-benefit analysis is sometimes
a component in making risk
management decisions, but it is only
one component. Frankly, 1 think it is a
legitimate consideration, particularly
when you arc; concerned about getting
the most environmental protection you
can from the resources you spend. But
clearly, risk management goes far
beyond cost-benefit analysis.
U The term "risk communication"
has been bandied about quite a bit
lately. What does it really mean, and
what is EPA trying to accomplish with
risk communication?
f\ Basically, risk communication
means talking and listening to the
public on three essential factors
pertaining to risk. These are: (1) the
environmental and health risks we are
trying to deal with in a given situation,
(2) the specific decision(s) we have
made, or are considering making, in this
situation, and (3) the reasons for our
proposed or final course of action. I
believe these factors are central to all
our risk communications, whether they
involve national policy-making or the
specific; risks at a particular Superfund
site.
I see risk communication as an
important part of EPA's responsibility. It
is a tool for educating the public: on the
nature of the risks the Agency is trying
to deal with, and how and why we
make our risk management decisions. It
is also a tool for us to get feedback from
the public on issues that concern them.
Beyond that, risk communication can
also serve to educate the public as to
what decisions they, as individuals, can
make to help manage risks in their
environment. The latter is an aspect of
risk communication the Agency has
begun to focus on just in the last couple
of years.
V_i But there seems to be a suspicion
in some sectors that EPA is trying to
persuade the public to accept risks that
they might not otherwise go along with.
r\ I think this perception relates to
the understandable reluctance of the
public to accept any risk. This point
strikes home to the most difficult
challenge of risk communication. Our
job is to explain what risks we are
dealing with, in a context that is
comprehensible to the public, Hut the
nature of risk is often difficult for us to
communicate, and difficult for the
public: to understand.
Putting risks in an understandable
context is very important. The polls
show that the vast majority of the public
supports strong environmental
protection. Yet in the same cities where
we find strong support for the
environment, frequently we also find
strong opposition to air pollution
control programs such as an inspection
and maintenance program for
automobiles. Why is that? I think one
major reason is that people do not fully
understand or appreciate the risks
associated with air pollution in their
city, and do not see the direct tradeoff
between the inconvenience of
complying with inspection/maintenance
requirements and the quality of the air
they breathe. Effective risk
communication can give the public: a
perspective for understanding risks and
also help people understand why the
part they are being asked to play in risk
management is important.
EPA JOURNAL
-------
m* ;»•* * <'^*m muz
Water pollution, one of the risks that EPA has major responsibilities for regulating. Such visible environmental problems are
becoming less frequent.
L2 As you see it, what is the best
medium for communicating risk?
r\ I think the best long-range strategy
for risk communication is what I would
call a grass-roots effort, carried out on
all levels—federal, state, and local. Risk
Communication needs to be an ongoing
effort, so that you keep people informed
at the various stages of a
decision-making process, whether you
are dealing with air pollution in a city,
water pollution in a community, a
Superfund site cleanup, or any other
environmental issue. It is important to
build understanding "from the bottom
up."
Generally, the public gets most of its
information on environmental issues
through the mass media—newspapers,
radio, television. For this reason,
working with media representatives to
ensure that they understand the
assumptions behind risk assessments
and the rationale for risk management
decisions is an extremely important part
of EPA's responsibility. Obviously, news
coverage of environmental issues has a
big impact on public perception. 1 have
seen articles that have not reported risk
well at all. On the other hand, I see a lot
of reports that I think are well
done—articles that do in fact explain
assumptions and place particular risks
in proper perspective, On the whole, I
think that if reporters are given all the
facts and the rationale for a risk
management decision, the majority do a
pretty good job in their coverage.
Li One more risk communication
question: what sort of lessons did we
learn from the Chernobyl incident
about risk communication?
r\ One major lesson we learned has
to do with being able to put risks in
context, and that is the importance of
collecting as much basic information
about a given risk as possible over a
substantial period of time. Fortunately,
in this instance, we had been collecting
information on radiation risk for years
in this country. We had a good base line
of data, so that we were able to explain
to the public; what the normal readings
were for water and milk, for example.
Then when we did see increases in
radiation levels, we were able to
compare these increases with levels that
we would consider to present any
significant risk. We would have been in
still a better position if we had
communicated basic radiation
information to the public beforehand.
Another lesson we learned from
Chernobyl is the imperative of
responding quickly and openly to
public: concerns about an emergency
situation.
Li Are you optimistic: that the risk
approach has enough momentum to go
on through the next administration?
r\ I don't think there is any question
about that. We have to set drinking
water standards, air standards, and
many other standards, and our ability to
do that is based on our assessments of
risks. Our job is to protect public health
and the environment, anil that puts us
in the business of making risk
management decisions. We have to be
able to characterize the environmental
problems that confront us. whether you
call it risk assessment or something else.
\~i Is EPA unique in its use of risk
assessment and risk management?
r\ Not at all. Essentially the same
concepts are being applied by other
regulatory agencies including the Food
and Drug Administration, the Consumer
Product Safety Commission, the Nuclear
Regulatory Commission, and the
Department of Labor's Occupational
Safety and Health Administration.
among others. I personally used risk
assessment and risk management
approaches and methodologies during
my tenure at the Federal Emergency
Management Agency. The technical
aspects were somewhat different from
the ones EPA is using, but the! concepts
of assessing and managing risk were
similar. Risk criteria are also being used
increasingly at state and local levels,
and in the international arena as well.
\J. What are some examples of how
risk assessment and management
approaches are being used
internationally?
r\ One of the best examples of risk
assessment and risk management at the
international level is the work we have
done with other countries on
stratospheric ozone depletion. Scientists
from EPA and around the world
collaborated in an effort to reach a
consensus on the risks of depletion of
the stratospheric o/.one layer, and the
potential effects of that depletion. And
we were able to reach a broad
consensus of the international scientific
community. Based on that consensus,
we were then able to frame policy
decisions for risk management on an
international scale. 1 think this
accomplishment has established a clear
precedent for dealing with international
environmental issues in the future, o
NOVEMBER 1987
-------
The Situation:
Institutional Problems
by Terry Davies
The United States is not well
prepared to deal with the current
environmental agenda, much less with
the agenda of the future. There has been
progress on some problems and in some
geographical areas, but currently,
stalemate and inaction characterize
much of the environmental policy
scene.
What we need is a better way of
understanding these problems, which
involves risk assessment; a better
understanding of the process of doing
something about these problems, which
includes risk management; and a better
way to carry on the public debate
regarding these problems, which
involves risk communication.
Consider the environmental problems
that are now on the agenda. Even a brief
list is sufficient to show how much
remains to be done; acid rain, pesticides
in food and water, too much ozone at
ground level and too little in the
EPA JOURNAL
-------
isle Royale National Park in Lake
Superior. Now that extensive water
pollution controls are in place for the
Great Lakes, it has been learned that
pollutants are also being deposited in
the lakes from the air, It is an example
of the complex problems now facing the
nation's environmental cleanup drive.
stratosphere, global temperature
wanning, draining of wetlands, slow
implementation of the Superfund
program, extinction of species, toxic
substances in all parts of the
environment. But to really understand
what's broken, it is necessary to
penetrate behind the myriad of specific
problems and examine what's wrong
with the institutions and processes the
nation relies on for environmental
protection.
Environmental policies are formulated
and implemented in the context of
pervasive mistrust, alienation, and
conflict. The problems of risk
communication described elsewhere in
this issue have their roots in the
alienation of the American people from
their government, and from other basic
institutions in society.
After 25 years of being told, and too
often shown, that government is part of
the problem, not part of the solution,
the American people have, not
surprisingly, come to believe it. The
belief not only poisons communication,
it also creates a vicious cycle: the
individuals and institutions of
government are held in low esteem;
government therefore has trouble
attracting qualified people and is
increasingly handicapped in
implementing programs, which results
in less effective and efficient
government. This in turn lowers the
public's respect for government still
more. Obviously, this problem affects all
public policies, not just environmental
policies, but until the advance of
alienation is reversed, we will not be
successful in protecting the quality of
the environment.
The gap in understanding and
communication between the public and
the pollution control agencies has deep
roots, which now include the very
conception of pollution itself. As Peter
Sandman has noted, "Over the past
several decades our society has reached
near-consensus that pollution is morally
wrong—not just harmful or dangerous,
not just worth preventing where
practical, but wrong." This view is not
shared by many in pollution control
agencies who must operate with limited
resources and who witness segments of
the public becoming agitated over
environmental problems which in the
view of the agency experts do not pose
serious dangers.
Congress is responsive to the public's
view that pollution is inherently evil.
The widening gap in understanding
between Congress and the Executive
agencies is aggravated and reinforced by
other factors. Congress expresses its
power through legislation, but most
members have no experience in the
problems of actually implementing
laws. Agency staff, on the other hand,
spend their entire working days
wrestling with implementation
problems, but have little experience
with balancing the types of political
pressures which make or break a
member of Congress.
The result is two very different
pictures of what needs to be done to
protect the environment and increasing
difficulty in communications between
the two branches of government.
Congress, not understanding
After 25 years of being told,
and too often shown, that
government is part of the
problem, the American people
have, not surprisingly, come to
believe it.
implementation, thinks that agencies
such as EPA are delaying taking action
for lack of commitment to the law.
Agency personnel, not appreciating
political pressures, think that Congress
is putting unrealistic and unworkable
provisions into law simply to win the
next election, not with any expectation
that the provisions will help the
environment.
As with our views of government
competence, the result of the
Congress-Executive split is a vicious
cycle. The laws are made increasingly
detailed and specific because Congress
believes the agencies won't take action
unless the laws are written this way.
Because the details and specifics do not
reflect a realistic understanding of
implementation requirements, each new
law seems more poorly implemented
than the last, feeding the mistrust of
Congress and resulting in still more
unrealistic laws.
The fragmented committee structure
within Congress and the fragmented
bureaucratic structure in the executive
branch also hamper environmental
protection. The narrow focus of
environmental programs is now a major
impediment to dealing with
environmental problems. Each of the
dozens of programs—underground
storage tanks, old hazardous waste sites,
new hazardous waste sites, indoor air
pollution, outdoor air pollution,
occupational air pollution, etc..
etc.—concentrates only on its narrowly
defined tasks, generally ignoring the
often critical interrelationships among
programs. Because these
interrelationships are ignored, much of
what passes for pollution control is. in
reality, simply shifting the pollution
somewhere else.
it is no accident that a large portion of
the current environmental problems
defies traditional categorization into air,
water, or land pollution. Acid rain.
global climate change, ground-water
contamination, toxic substances,
hazardous waste, and other problems do
not fit into the traditional way pollution
control programs have been organized.
The creation of new single-focus
programs only exacerbates the
fragmentation and the failure to
recognize the key importance of
ecological interrelationships.
The Office of Policy Analysis and
some other parts of EPA have tried to
overcome the self-defeating maze that
now exists. Utilizing the common
metric of risk is an important step
forward in overcoming the current
fragmented approach. The EPA staff
report on Unfinished Business, released
earlier this year, found serious
mismatches between Agency priorities
and the degree of risk to the
environment and human health. But
analytical approaches by themselves
will not bring about more integration.
Fundamental changes in concepts, in
laws, and in the organization "f both the
legislative and executive branches will
be required to deal adequately with
current and future environmental
problems. These changes will not be
easy to effect, but they arc absolutely
essential.
Increasing numbers of environmental
problems require international
cooperation for their solution. Some of
these problems, like stratospheric ozone
depletion and climate warming, are
obviously global in scope. Some, such
as pesticides and acid rain, arise
because we are discovering that
substances can be carried much longer
distances than previously thought. And,
not least, the growing extent of
international trade and the spread of
NOVEMBER 1987
-------
sophisticated technology turn what were
once local or national problems into
international ones.
It is much more difficult to deal with
international problems than with
national ones. Unfortunately, the
weakness of international institutions to
protect the environment and the jealous
defense of national sovereignty mean
that even if nations can agree on
cooperative measures, it will he very
difficult to implement such measures.
The worst environmental conditions
are to be found in the developing
countries. The United States and other
developed nations cannot ignore these
conditions, for national security ;md
humanitarian reasons. A degraded
environment in any one country can
pose a threat to the environment of
other countries, Misuse of pesticides in
Central America can result in
contaminated food on American tables.
Loss of tropical forests can deprive the
world of potentially valuable species.
Increased knowledge about the
long-range transport ol pollution also
poses problems among the 50 states.
The basic U.S. pollution control laws
relv on the states for their
Tho U.S. Congress. This body and EPA
c-ijoh play key roles in determining how
environmental risks are addressed.
implementation, and they are premised
on the damage caused by pollution
being felt mostly by the state in which
the pollution arises. Acid rain clearly
violates this premise, which is one
reason that it has been so difficult to
reach agreement on control measures.
But acid rain is not unique. More likely
it is the prototype of the environmental
problems of the future. The disparity
between the scope of environmental
problems and the jurisdiction of the
governments that must deal with the
problems will become an increasingly
acute weakness in our attempts to
improve environmental quality.
The federal government has
increasingly turned over to the states
responsibility for dealing with
environmental problems. In recent years
we have been in one of our periodic
pendulum swings toward greater
decentralization and state power. That
the pendulum will swing the other way
can be predicted with near certainty.
But the scarcity of money, which has
driven much of the current swing to tin:
states, will not be so easily reversed.
The federal budget has been "busted" by
the past six years of huge increases in
government expenditures combined
with the failure to raise taxes to pay for
the increases. Dealing with
environmental problems takes money,
and if the economic system is broke,
then the environmental control system
will likely be broken.
All of the weaknesses described above
are affected and made worse by an
underlying problem—the lack of
scientific knowledge about the causes
and effects of environmental
degradation. Scientific knowledge does
not determine environmental policy
decisions—economic and political
factors are likely to be equally or more
important. But the political and
economic factors themselves derive
from an understanding of the nature of
the problem, an understanding that is,
or at least should be, based on science.
It is hard to exaggerate the extent of our
ignorance about environmental
problems, and current research efforts
are woefully inadequate.
This article has dwelt on "what's
wrong." There are also aspects of
current environmental efforts that work,
but description of these was not part of
the author's assignment. Unfortunately,
those aspects of our efforts that are
wrong are quite fundamental, and until
they are fixed we cannot expect to be
successful in protecting environmental
quality, a
(Dr. Davies is Executive Vice President
of The Conservation Foundation,J
EPA JOURNAL
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The Situation:
What The Public Believes;
How The Experts See ft
by Frederick W. Allen
Kenneth Garret!. Woodfin Camp fnc
Spraying pesticides on a crop.
Consumer risks from pesticides were
given a high ranking by EPA experts in
the Agency's comparative risk report,
but received a lesser ranking by the
public in polls.
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. Indeed, risk estimates
by "experts" and lay people (or "the
public") on many key environmental
problems differ significantly.
This problem and the reasons for it
are extremely important, because in our
society the public generally does not
trust experts to make important risk
decisions alone. As former EPA
Administrator William D. Ruckelshaus
has said, "We have decided, in an
unprecedented way, that the
decision-making responsibility
involving risk issues must be shared
with the American people, and we are
very unlikely to back away from that
decision. "The policy questions at stake
are critical, affecting not only public
and ecological health and welfare, but
also massive amounts of public and
private resources."
This situation was illustrated by a
recent EPA study. In February 1987,
EPA released a report entitled
Unfinished Business: A Comparative
Assessment of EnvironnientciJ Problems.
(See EPA Journal, May 1987.] HPA
Administrator Lee M. Thomas had
commissioned this study nearly a year
earlier to "compare the risks currently
associated with major environmental
problems, given existing levels of
control." Thomas' explicit premise was
that "in a world of limited resources, it
may be wise to give priority attention to
those pollutants and problems that pose
the greatest risks to our society."
To assess and compare these
problems, KI'A created a special task
force of about 75 career managers and
experts from all Agency programs. The
task force compared four different types
of risks existing now for each of 3 1
environmental problem areas: cancer
risk, non-cancer health risks, ecological
effects, and welfare effects (e.g.,
materials damage). While the task force
did not try to "weight" or "add" the
different types of risks for problem
areas, they did develop rough rankings
of problems within risk types. (See
box on page 11 ,J
NOVEMBER 1987
-------
People often overestimate the
frequency and seriousness of
dramatic, sensational,
dreaded, well-publicized
causes of death and
underestimate the risk from
more familiar, accepted
causes.
Beyond these rankings, the task force
made no assertions about what KPA's
priorities ought to be, noting that
policymakers must consider many other
factors besides risk when they set
priorities, such as legislation, economics,
technology, and public mandate.
The examination of public mandate
raised some interesting issues. A rough
analysis of recent public polling data by
the Roper Organization on
environmental problems made it clear
that KPA's actual priorities and
legislative authorities correspond more
closely with public opinion than they
do with the EPA task force's estimates
of the relative risk. (See Box.) The most
.significant differences concern
hazardous waste and chemical plant
accidents (high public concern.
medium/low risk ranking by the task
force) and pesticides, indoor air
pollution, consumer product exposure,
worker exposure to chemicals, and
global warming (medium/low public
concern, relatively high risk ranking by
the task force].
Why The Differences?
The most obvious reason for the
differences is that the general public
simply does not have all the
information that was available to the
task force experts. The subject is vast
and it is hard for anyone to have full
knowledge of the information. Indeed,
the experts themselves had to go to
considerable effort to develop their
rankings, and all of them were surprised
by at least some of the findings.
Beyond this fact, it is interesting to
observe that the judgments expressed in
the polling data are consistent with an
important finding by various
researchers: as mentioned at the
beginning of this article, people otten
overestimate the frequency and
seriousness of dramatic, sensational,
cireaded, well-publicized causes of
death and underestimate the risks from
more familiar, accepted causes that
claim lives one by one. The EPA report
should help people gain a better
knowledge of the information and help
close the gap between the experts and
the public.
It is also important to note that the
experts and the public were answering
somewhat different questions. The EPA
task force purposely dealt with a limited
number of dimensions of risks, ignoring
most of the intangible aspects that are of
great value to the public: the degree to
which risks are familiar, generally
accepted, voluntary, controllable by the
individual, etc:. These differences reflect
a more general pattern of experts taking
a societal (macro) perspective, while the
lay public: usually takes a more
individual or personal (micro)
perspective.
These factors provide important
additional insights in explaining the
differences between the task force's
relative rankings and the public's.
Hazardous waste disposal provides the
most dramatic illustration. Recognizing
the degree of public concern on this
issue, the task force double-checked its
rankings of active and inactive
hazardous waste sites. The task force
noted that in certain locations
hazardous waste does pose a very
serious risk, but relatively few people
live near enough to be directly affected.
Thus the total national impacts on
public health and welfare and
environment do not match the national
concern. The intrusive, involuntary
nature of the risk, the fact that
slow-moving ground water can stay
polluted for a very long time, the
presence of any identifiable "scapegoat,"
and the difficulty many people have in
seeing any overriding benefit to having
a hazardous waste site nearby are also
important factors.
Interestingly enough, the fact that
hazardous waste is only a problem in
some locations has not been lost on the
public. While 76 percent of the people
interviewed by Roper called chemical
waste disposal a "most serious"
environmental problem and the same
percentage said there is not enough
regulation of industrial toxic waste, only
36 percent were aware of toxic waste
problems in their own communities and
only 16 percent considered toxic wastes
to be near enough to their homes to be a
threat to their personal health.
In contrast, indoor air pollution,
consumer product exposure, and, to
some extent, pesticides problems and
worker exposure to chemicals are risks
to which nearly everyone is exposed.
The task force ranked these risks
relatively high, yet the public ranked
them medium/low. These 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 substances causing
each of these problems are clear.
Global wanning was also ranked low
by the public and relatively high by the
task force. However, this appears to be a
somewhat special case. The task force
ranked it high because of the massive
potential implications for the entire
world. The most probable explanation
of the low public ranking is threefold:
(1) the consequences are very much in
the future and hard for many to imagine
because they extend beyond ordinary
experience, (2) the problem is diffuse
and there are many causes (the
"scapegoat" problem), and (3) there is
simply a general lack of public
The Valley of the Drums in Kentucky,
one of the hazardous waste sites that
gained early renown. Hazardous waste
ranks high in public concern in polls.
EPA experts agreed that it poses serious
risks at various locations, but ranked it
as a relatively medium to low risk to the
population at large.
10
EPA JOURNAL
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Courier-Journal and Louisville Times Co
.*,
> '
fi
How EPA Experts
Rank Environmental
Risks—Highlights
Overall High/Medium Risk
• "Criteria" air pollution from
mobile and stationary sources
(includes acid precipitation)
• Stratospheric ozone depletion
• Pesticide residues in or on foods
• Runoff and air deposition of
pesticides
High Health;
Low Ecological
and Welfare Risk
• Hazardous/toxic air pollutants
• Indoor radon
• Indoor air pollution other than
radon
• Drinking water as it arrives at
the tap
• Exposure to consumer products
• Worker exposures to chemicals
Low Health;
High Ecological and Welfare Risk
• Global wanning
• Point and nonpoint sources of
surface water pollution
• Physical alteration of aquatic
habitat (including estuaries and
wetlands) and mining waste
Overall Medium/Low Risk
(Ground-Water-Related Problems)
• Hazardous waste sites—active
(RCRA)
• Hazardous waste sites—inactive
(Superfund)
• Other municipal and industrial
waste sites
• Underground storage tanks
Mixed and/or Medium/Low
Risk
• Contaminated sludge
• Accidental releases of toxic
chemicals
• Accidental oil spills
• Biotechnology (environmental
releases of genetically altered
materials)
Source: Unfinished Business: A
Comparative Assessment of
Environmental Problems (EPA
1987 J
How the Public Ranks
Selected Environmental
Risks
High Risk
• (1) Chemical waste disposal
• (2) Water pollution
• (3) Chemical plant accidents
• (4) Outdoor air pollution
Medium Risk
• (5) Oil tanker spills
• (6) Exposure to pollutants on the
job
• (7) Eating pesticide-treated food
• (8) Other pesticide risks
• (9) Contaminated drinking water
Low Risk
• (10) Indoor air pollution
• (11) Exposure to chemicals in
consumer products
• (12) Genetic engineering
(biotechnology)
• (13) Waste from strip mining
• (14) Non-nuclear radiation
• (15) "Greenhouse effect" (CO2
and global warming)
Source: Original data drawn from
1984-86 polls conducted by the
Roper Organization, Inc.
-------
Should the government focus
available resources and
technology where they can
have the greatest tangible
impact or should it focus them
on those problems about
which the public is most
upset?
familiarity with the issue. If more
people knew about global warming, its
implications would probably cause
them to rank it much higher. This is a
"new" issue and although polling data
are not yet available to confirm it, the
level of concern appears to be rising.
What are the implications?
The most obvious message for those
involved in environmental
problems—representatives of
government, industry, public interest
groups, and the science community—is
to recognize how people may react to
the risks, to understand why the risks
have been assessed technically as high
or low, and to tailor policies and
communications to accommodate
differing perspectives.
Issues of high risk/high public
concern and low risk/low public
concern are issues of general agreement.
But the high/low combinations can
present challenges of leadership, values,
and ethics to all involved.
The high-risk/low-concern problems
tend not to excite the public, in seeming
contradiction of the data developed by
the experts. These are hard cases for
government officials, where the experts
are suggesting they act on the basis of
facts or scientific projections, rather
than on public mandate. The situation
can be especially difficult when the
remedies are complicated and expensive
and there are other competing demands
for resources. As it turns out, experts
from the science community often have
a special credibility in these cases,
particularly when the problem is "new"
to the public agenda. Public interest
groups and the press can also play an
important role. In these instances,
clearly presented facts that are relevant
to individual circumstances are
essential. At the same time, however,
those presenting the facts in the hope of
raising public interest have a
responsibility not to raise anxiety to an
unjustified level.
On the other hand, the
low-risk/high-concern problems present
different issues, especially to those
considering national priorities. The first
issue to confront is how many
individuals are in the high-risk category
and how high is the risk? The next issue
concerns equity. We must ask whether
the hazard to a relative few from an
identifiable source(s) is justification
enough to give the problem high
priority and a generous share of
resources. The answer may be yes or no.
A third issue is how to reply to people
who are concerned about a problem that
the experts claim presents relatively less
hazard than another, especially when
resources to deal with both are limited.
There is always a temptation not to
face these issues. It is hard to ignore the
will of the people, particularly when the
sentiments are firmly held and not
easily changed. Indeed, they raise some
even more fundamental issues
concerning the proper role of a
democratic government (and other
organizations in a democracy) when it
comes to issues of risk. Put crudely,
should the government focus available
resources and technology where they
can have the greatest tangible impact on
human and ecological health and
welfare, or should it focus them on
those problems about which the public
is most upset? (After all, anxiety and
fear are very real to those who are
affected.) Put more pragmatically, what
is the proper balance? Does the severity
of the problem make a difference? How
about the qualitative aspects of the risk?
(For that matter, is the answer the same
for different qualitative aspects:
individual vs. population risk; dread of
the unknown vs. acceptance of the
commonplace; presence of a
"scapegoat"; voluntariness of exposure;
equity in incidences of harm or cost,
etc.?) Is the answer the same for the
legislative and executive branches? Is
the answer the same at the site-specific
and national levels?
Obviously there are no clear answers
to these questions. However, it is
becoming clear to both experts and the
public that they each have something to
offer concerning how we view risk.
Many risk experts who have been
accustomed to looking at numbers and
probabilities are now conceding that it
is clearly rational to look at risk in
broader terms. At the same time, the
public is being supplied with more risk
data to enable them to make more
informed judgments.
What is happening now is that the
concepts and tools are being developed
to understand and communicate both
tangible and intangible aspects of risk
more explicitly so that people who
begin with different viewpoints can
come to a common understanding more
easily. This is where the recent
emphasis on risk assessment, risk
management, and risk communication,
the EPA project described in this article,
and indeed this whole issue of EPA
Journal come together. Together they
make it easier to deal with issues that
hinge on data, probabilities,
assumptions, and tradeoffs, and in turn
make it easier to frame issues of social
values for real public discussion.
Achieving this goal is not an easy or
short-term task, but the stakes—health,
welfare and society's resources— make
it worth the effort, a
(Allen is Associate Director of EPA's
Office of Policy Analysis. He was a
member of the EPA task force described
in this article.)
12
EPA JOURNAL
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Test being performed on a laboratory
rat. Animal tests provide much of the
data that EPA uses in assessing
environmental risks.
Risk
Assessment:
What tt Is;
How tt Works
by Warner North and
Terry F. Yosie
Risk assessment has emerged as a
major, if not the dominant,
analytical tool in supporting
environmental decision-making within
EPA. The growth in the use of risk
assessment has resulted from EPA's
need for increased sophistication in
developing regulations mandated by
statute, and improved ways to
communicate the scientific: basis for
decisions to the public. While EPA's use
of risk assessment has accomplished
some major successes, it should he
anticipated that risk assessment
methods and practice will undergo
considerable expansion and refinement
in the coming years.
Risk assessment may be defined as
the characterization of potential adverse
effects to humans or to an ecosystem
resulting from exposure to
environmental hazards. Risk assessment
supports risk management, the choices
on whether and how much to control
future exposure to the suspected
hazards. Risk managers face the
necessity of making difficult decisions
involving uncertain science, potentially
grave consequences to health or the
environment, and large economic effects
on industry and consumers. U'hat risk
assessment provides is an orderly.
explicit, and consistent way to deal
with scientific issues in evaluating
whether a hazard exists and what the
magnitude of the ha/.ard may be. This
evaluation typically involves large
uncertainties, because the available
scientific data are limited, and the
mechanisms for adverse health imp,ids
or environmental damage are only
imperfectly understood.
Over the past decade risk assessment
has had its largest impact in regulatory
practices with respect to carcinogens.
As we have accumulated evidence that
a large number of common chemicals
are mutagenic or give positive results in
rodent bioassays, a regulatory
NOVEMBER 1987
13
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Despite the expanded use and
increased sophistication of
risk assessment, there are
many areas where research
can lead to improved methods
and practices.
philosophy based on banning such
substances from the ambient
environment has become less and less
feasible. Risk assessment for carcinogens
has provided a means to evaluate and
compare the magnitude of the threat to
health posed by a large number of
suspected carcinogens present at low
levels in air, water, and soil.
EPA has played an important
leadership role among federal agencies
in pioneering methods to categorize the
evidence that a chemical substance is
carcinogenic in humans and to make
quantitative estimates of the extent of
cancer that could result from a given
level of exposure. EPA's methods for
carcinogen risk assessment were first
published in the scientific literature
more than a decade ago. These methods
were important influences on federal
interagency efforts to establish
regulatory practices for carcinogens. The
National Academy of Sciences' (NAS)
widely cited 1983 Report, Risk
Assessment in the FederaJ Government:
Managing the Process, endorsed many
of the practices that EPA had evolved
for carcinogen risk assessment, such as
the preparation of formal scientific
documents summarizing the available
scientific information and the practice
of having such documents undergo peer
review by an outside group of scientific
experts.
As a means of facilitating uniform
practices for using available scientific
information and for increasing public
credibility of a process that requires
extensive reliance on judgment in the
absence of data, the NAS recommended
that uniform guidelines be established
for risk assessment. Interagency
principles for carcinogen risk
assessment have subsequently been
developed under the leadership of the
Office of Science and Technology Policy
of the Executive Office of the President.
EPA has published its own guidelines
in the Federal Register, not just for
carcinogenicity, but also for the
assessment of other health effects
(mutagenicity, developmental effects),
for exposure assessment, and for dealing
with the health effects of chemical
mixtures.
Risk assessment methods for
carcinogens and other chemicals
suspected of causing adverse human
health effects are now widely used
within EPA and by many environmental
agencies at the state and local levels.
These methods have been used to
project the potential health
consequences of exposure to a large
number of chemical substances found in
the ambient environment. The decisions
to continue registration of a pesticide, to
list substances as hazardous air
pollutants under Section 112 of the
Clean Air Act, or to regulate water
contaminants under the Safe Drinking
Water Act now depend in large part on
EPA's risk assessments for the
substances in question.
Risk assessment methods are being
used to set regulatory priorities as well
as to support regulatory actions. EPA's
February 1987 report, Unfinished
Business: A Comparative Assessment of
Environmental Problems, has initiated a
dialogue at the national level on the
relationship between risk assessment
and priority setting. The Integrated
Environmental Management Program
within EPA's Office of Policy Analysis
has worked with state, local, and citizen
groups to apply risk assessment to air
toxics, indoor radon, ground-water
contamination, and drinking water
supplies in areas as diverse as
Philadelphia, Denver, Baltimore, and
Santa Clara Valley, California.
Assessment of exposure is an
important component of risk
assessment, and EPA is evolving
improved procedures to carry out
exposure assessment. EPA's Total
Human Exposure research program has
provided important new information
concerning human activity patterns in
indoor and ambient environments and
new insights into the importance of
pollutant exposure indoors and
outdoors. There is also a growing
appreciation within the scientific
community of the role of indirect
pathways as a means of human
exposure. For example, deposition of
lead particles in dust or soil and
subsequent ingestion through
hand-to-mouth contact is a major
exposure pathway and, therefore, health
risk, especially for children.
Despite the expanded use and
increased sophistication of risk
assessment, there are many areas where
research can lead to improved methods
and practices. The rapidly expanding
understanding of the molecular basis of
cancer and other health effects offers the
potential that the large uncertainties
now present in risk assessment may be
reduced. More accurate procedures
based on knowledge of biological
mechanism may replace the current
procedures for scaling doses from
laboratory animals to humans and for
extrapolating from high doses to the
much lower doses characteristic of
ambient exposure levels.
The scope of risk assessment is also
expanding. There are active efforts
underway in EPA and in the scientific
community to expand risk assessment to
include health endpoints such as
immunotoxicity, neurotoxicity,
reproductive effects, and adverse
14
EPA JOURNAL
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Risk assessment can play an
increasingly important role in
educating the public on the
nature and degree of
environmental risks that
confront them.
changes in specific organs, such as the
kidney, liver, and lung. The Office of
Air Quality Planning and Standards has
developed the use of probability
methods to assess the judgment of
scientific experts on uncertainties
regarding the health effects of low levels
of lead in children. Such methods for
characterizing uncertainty explicitly are
a promising alternative to the use of
conservative or plausible upper-bound
estimates for uncertain quantities.
Other examples of research conducted
by EPA and other research institutions
to improve scientific data and methods
include the following:
• Extrapolation modeling—the process
of projecting effects in humans based
upon observations derived from
controlled animal studies. Examples of
work underway include: extrapolation
between species, testing subpopulations
of differing sensitivity, interpolation
between doses, extrapolation across
durations of exposure and between
developmental stages.
• Pharmacokinetics—the study of the
absorption, metabolism, distribution,
and elimination of foreign substances
from the body. EPA's inhalation
toxicology research program has
developed ozone dosimetry models to
simulate local absorption of ozone in
the lower respiratory tract. Agency
researchers are also presently
investigating pharmacokinetic analysis
to analyze the consequences of changes
in the cadmium level in the food
supply.
• Development of toxic equivalency
factor (TEF) methodologies for
assessing mixtures of untested (or
incompletely tested) compounds on the
basis of structure-activity relationships.
EPA has developed a peer-reviewed
interim methodology for assessing the
health risks of dibenzo-p-dioxins and
dibenzofurans.
• Ecological risk assessment—
the development of a
formal approach to characterize
scientific knowledge of the risk to
ecological systems following exposure
to environmental contaminants.
• Assessment of the consequences of
stratospheric ozone depletion. EPA staff
developed a summary of applicable
scientific data and a quantitative
integrating model for projecting human
health and ecological impacts from
changes in ultraviolet radiation that
could result from changes in the ozone
layer of the stratosphere. This risk
assessment supported the EPA and
other U.S. representatives in the
negotiation of the recent Montreal treaty
for worldwide limitation of
chlorofluorocarbon emissions to protect
the stratosphere.
Risk assessment can play an
increasingly important role in educating
the public on the nature and degree of
environmental risks that confront them.
Over the past 25 years the public
awareness of environmental risks has
risen dramatically, and the scope of the
public concern extends across the
nation and the range of EPA's regulatory
activities. It applies to hazardous waste
sites in New Jersey, to pesticide
applications in Kansas, and to the
issuing of permits to biotechnology
companies in California.
EPA is taking actions in an attempt to
improve understanding of the public's
perceptions about risk. The Agency is
also using risk assessment as a way to
articulate the scientific basis for its
actions to reduce risks. Such efforts
include a trend toward greater
involvement of EPA scientists and
analysts in working directly with
affected communities and groups. The
Agency has sponsored meetings to
encourage Pennsylvania citizens to
inform themselves about indoor radon,
and to express their perceptions
regarding what actions they and
government agencies might take to
reduce this hazard. Risk communication
conferences are used to explain to
representatives of the media, to
environmental and industry groups, to
members of the scientific community, to
Congress, and to individual citizens
how EPA uses scientific data in making
regulatory decisions.
Risk assessment provides a means of
presenting and evaluating scientific
information and uncertainties, so that
both decision-makers and the affected
public can better understand the basis
for environmental risk management
decisions that EPA and other regulatory
agencies are charged with making under
existing environmental statutes. The
science supporting environmental
regulatory decisions is complex and
evolving rapidly, and many of the most
important threats to human health and
the environment are highly uncertain.
Risk assessment can help in establishing
a common basis of knowledge and
uncertainty, so that EPA and other
institutions can carry out the needed
research, planning, and decision-making
in a way that is consistent with both
science and the public's concern for
environmental protection, o
(Dr. North is Principal of Decision
Focus, Inc., and a member of the
Environmental Health Committee of
EPA's Science Advisory Board and
Dr. Yosie is Director of the Science
Advisory Board.].
NOVEMBER 1987
15
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Risk Management:
FIFRA and the Dinoseb Case
by Karen Flagstad
The Federal Insecticide,
Fungicide, and Rodenticide Act
(FIFRA), which governs KPA's
regulation of pesticides, is often called a
"balancing" statute because it requires
the Agency to weigh the risks of
pesticides against their economic and
social, benefits when making regulatory
decisions. Under FIFRA, all pesticides
intended for use in the United States
must be registered (licensed) by KPA to
ensure that they do not cuuse
"unreasonable adverse effects on the
environment." In the context of FIFRA,
unreasonable adverse effects are defined
to menu: "any unreasonable risk to man
or the environment, taking into account
the economic, social, and environmental
costs and benefits oi the use of any
pesticide."
The risk/benefit mandate of FIFRA
makes pragmatic sense when you
consider that pesticides, almost by
definition, yield risks as well as
agricultural and other pest-control
benefits. Since pesticides typically
perform their intended function becmise
they are toxic to something, there is
generally no such thing as a "/.ero risk"
pesticide. Reflecting Congress'
recognition that pesticide uses involve
tradeoffs between benefits and risks,
FIFKA calls upon FPA to make
administrative judgments as to how
much risk is reasonable in light of the
specific benefits to be obtained from
pesticide uses.
Registration under FIFRA is a license
for the sale of a pesticide for use on a
specific crop or other site under the
circumstances prescribed by its
approved labeling. Pesticide registration
is not an "either or" proposition
whereby KPA either gives blanket
approv.il to the sale and use of a
pesticide, or else disapproves its
registration. On the contrary, in cases
where proposed or continued uses of a
pesticide raise risk concerns, FIFRA
affords EPA a spectrum of risk
management options to bring down
risks, wherever possible, with limited
impacts on benefits. Depending on the
nature of EPA's concerns, such options
might include: requiring protective
apparel and/or equipment to minimize
risks to pesticide applicators; reducing
the rate or frequency of application or
otherwise modifying application
practices to lower pesticide residue
levels on harvested crops; or imposing'
regional restrictions against using a
pesticide in areas where it could leach
into ground water.
On a graduated scale of risk
management options available under
FIFRA, regulatory action by EPv\ to
remove some or all uses of a pesticide
from commerce by initiating
cancellation proceedings is an option of
last resort. Yet there are cases where
EPA does opt to cancel a pesticide, or
even call an immediate halt to its use
for the duration of formal cancellation
proceedings—most recently in the case
of dinoseb, a chemical with herbicidal,
fungicidal, insecticidal. and desiccant
properties that has been widely used in
recent decades, primarily in agriculture.
On October 7, 1986, the Agency-
issued a formal notice of intent to
cancel and deny all registrations for
pesticide products containing dinoseb,
citing evidence that it may cause birth
defects in children born to women
exposed to dinoseb during pregnancy,
and may also cause sterility or
decreased fertility in males, acute toxic
poisoning, and other potential adverse
effects on health and the environment.
On the same day, EPA issued an
emergency suspension order effecting an
immediate stop to dinoseb use during
the time required to complete
cancellation proceedings on the
pesticide, (Under FIFRA, an "emergency
suspension" takes effect immediately,
whereas under an "ordinary
suspension," pesticide registrants may
request an expedited hearing be/ore the
suspension takes effect.) The dinoseb
order was the third such emergency
suspension order EPA has issued under
FIFRA.
Let's consider the case of dinoseb in
the context of EPA's pesticide risk
assessment and risk/benefit "balancing"
process.
Dinoseb Risk Assessment
What were the studies that led to EPA's
emergency suspension and cancellation
initiatives on dinoseb, and how did EPA
use these studies for risk assessment?
• Birth Defects. In recent laboratory
studies, dinoseb has caused birth
defects in the offspring of three test
animal species (rabbits, rats, and mice).
Based on this multi-test evidence from
studies using several different routes of
exposure, EPA scientists concluded that
dinoseb causes birth defects in
laboratory animals and has the potential
to cause birth defects in humans. Based
on statistical data from the rabbit study
(an oral feeding study), a "No Observed
Effects Level" (NOEL) was provisionally
set at 3 milligrams per kilogram of body
weight per day (mg/kg/day)—meaning
that adverse effects in test animal
offspring were apparent at all oral
exposure levels higher than 3
mg/kg/day.
• Male Reproductive! Effects. In rodent
feeding studies, dinoseb has caused
adverse reproductive effects in males.
Based on the evidence in mice and rats,
EPA scientists concluded that dinoseb
causes adverse reproductive effects in
laboratory animals and should be
:>
EPA JOURNAL
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considered a potential cause of human
male reproductive disorders.
• Acute Toxicity. The LD50 of a
pesticide (the dose at which 50 percent
of test animals succumb to the toxicity
of the chemical) is typically used as a
measure of its acute toxicity. Test data
cited by EPA in its dinoseb suspension
and cancellation notices showed the
dinoseb LD50 by dermal exposure to be
approximately 75 mg/kg—an LD50 low
enough to be considered indicative of
very high toxicity. There is also direct
evidence of the acute toxicity of dinoseb
in humans, including at least one
human fatality attributed to accidental
exposure to dinoseb during spray
application.
In addition to the effects just
described, dinoseb belongs to a class of
chemicals (dinitrophenols) known to
induce cataracts in humans, and
cataracts have been observed in the eyes
of three species of laboratory animals
following dinoseb exposure. Dinoseb
has also induced tumors in female mice
and may have the potential to affect the
immunological system. Apart from its
potential human health effects, dinoseb
also has the potential to adversely affect
wildlife.
The toxicity profile just outlined
raises very significant concerns
regarding the teratogenicity (birth
defects) and other hazards of dinoseb.
On the other hand, from the standpoint
of pesticide risk assessment, the
toxicological characteristics of a
pesticide chemical are only half the
picture. The second basic component of
risk is the extent to which people and
the environment are actually exposed to
FIFRA affords EPA a
spectrum of risk management
options to bring down risks,
wherever possible, with
limited impacts on benefits.
the pesticide when it is used in
accordance with widespread and
commonly recognized practice.
In the case of dinoseb, three basic
exposure scenarios were identified:
• Possible dietary exposure to the
public through consumption of food or
drinking water containing residues of
dinoseb.
• Occupational exposures to workers
who mix, load, or apply dinoseb.
• Secondary or "coincidental"
exposures to bystanders, farmworkers,
and others who could be exposed to
dinoseb through spray drift, contact
with residues in treated fields, or even
contact with contaminated clothing or
farm equipment immediately after
dinoseb application.
In conducting pesticide risk
assessments, as in the case of dinoseb,
EPA makes a practice of evaluating all
potential toxic effects, but generally
focuses its quantitative risk assessment
and risk/benefit balancing process on
the effect observed at the lowest dose
level. For dinoseb, this was the 3
mg/kg/day NOEL cited earlier for
dinoseb-induced birth defects in rabbit
offspring. In quantitative calculations,
EPA scientists compare this NOEL from
laboratory studies with expected human
exposure levels to obtain numerical
"margins of safety" (NOEL divided by
exposure equals margin of safety, or
MOS). To protect people from
significant health risks, EPA generally
considers an MOS greater than 100 to be
acceptable when calculated from animal
data. Where an MOS is less than 100,
the Agency typically considers the
comparative impacts of possible risk
management measures.
• Risks from Dietary Exposure. EPA
scientists calculated MOS values for
risks of birth defects from potential
dietary exposure to dinoseb residues in
food and drinking water. Even when
certain "worst case" assumptions
regarding dietary exposure levels were
factored into these calculations, the
MOS for the risk of birth defects
occurring from consumption of foods
from crops treated with dinoseb was
found to be ample—over 2700.
Similarly, from consumption of drinking
water in areas where dinoseb may have
leached to underground aquifers, the
MOS was roughly 2450.
• Risks from Occupational Exposures to
Dinoseb. Based on experimental data
from field studies performed with
dinoseb and other agricultural
pesticides, exposure levels were
estimated for the various kinds of
workers involved in the use of dinoseb
on various crops sites: mixer/loaders,
pilots, airplane flaggers, "ground boom"
applicators, and hand-sprayers. For
these various kinds of workers,
exposure levels were estimated for a
range of plausible exposure conditions.
In many instances, estimated worker
exposure levels were equal to or greater
than the NOEL of 3 mg/kg/day for birth
defects in test animals treated with
dinoseb. If a worker is exposed to a
pesticide at a level that is equal to its
NOEL in laboratory animals, he or she
is said to have an MOS of 1. Thus, in
NOVEMBER 1987
17
-------
For all crops and use sites,
based on all available risk
data and benefits information,
the risks of continued use of
dinoseb were deemed to
outweigh the benefits.
the case of dinoseb, the Agency found
virtually no MOS against the occurrence
of birth defects in pregnant workers
handling the pesticide.
• Risks from Secondary Exposure to
Dinoseb. EPA did not have adequate
exposure data to calculate MOS values
for secondary exposures to dinoseb.
However, there are grounds for inferring
that significant secondary exposures do
occur, including data from the State of
California revealing that acute
poisonings from spray drift of
dinitrophenol pesticides occur annually.
Dinoseb Benefit Assessment
Based on data from the U.S.
Department of Agriculture and other
sources, EPA conducted an assessment
of the benefits of dinoseb by calculating
the short-term and long-term economic
impacts expected to occur if dinoseb
were unavailable for registered uses.
Dinoseb use sites included soybeans,
peanuts, cotton, snap beans, potatoes,
green peas, grapes, alfalfa, almonds and
walnuts, berries, hops, non-crop areas,
and a variety of "minor use" crops and
sites.
For both short- and long-term
scenarios, estimated economic losses
were due mainly to increased pest
control costs and expected yield losses
for some crop sites. For both scenarios,
the largest user impacts were projected
for potato and peanut growers, while
the extent of impacts on the production
of green peas, snap beans, caneberries,
and hops were uncertain. Apart from
these uncertainties, the overall annual
impacts of removing dinoseb from the
marketplace were estimated at the user
level in the range of $80 to $90 million.
The information available to EPA did
not point to significant market and
consumer impacts, except for possible
short-term peanut price increases.
Regulatory Options Considered
In the case of dinoseb, EPA was
satisfied that there were adequate
margins of safety to protect public
health from any risks due to dietary and
drinking-water exposures to the
pesticide. On the other hand, the
Agency's MOS calculations pointed to
extraordinarily high risks of birth
defects from occupational exposures to
dinoseb, and there was reason to believe
that secondary exposures to dinoseb
also presented significant risks to
unborn children. The evidence available
to EPA also indicated that occupational
and secondary exposures to dinoseb
posed additional risks of adverse
reproductive effects in males and acute
toxic poisoning. Focusing on these
exposure routes, EPA considered a
number of possible risk management
options to determine whether such
measures could reduce the risks of birth
defects and other potential adverse
effects to acceptable levels in view of
the known benefits of dinoseb.
• Additional Protective Clothing. The
risks of birth defects in children bom to
workers involved in the use of dinoseb
were found to be unacceptable even
with the protection afforded by the
requisite apparel specified by dinoseb
product labels: goggles or a face shield,
impermeable gloves, and an apron when
handling dinoseb concentrate; and
long-sleeved shirts, long-legged pants,
and shoes and socks when handling the
concentrate or spraying the prepared
formula. To further minimize worker
exposure, the Agency considered the
possible additional requirement of
Tyvek® suits (synthetic, disposable
coveralls) for workers who handle
dinoseb. However, EPA decided against
this special requirement, due in part to
practicality and enforcement problems.
In addition, the Agency had concerns
about the hazards of heat stress that
may result when this type of synthetic
clothing is worn in temperatures above
80 degrees Fahrenheit.
• Protective Form Equipment. As part
of the exposure and risk assessment of
dinoseb, EPA scientists calculated MOS
values for workers with and without the
use of such protective farm equipment
as closed loading systems and enclosed
tractor cabs. Although MOS values were
higher with the use of this equipment,
they were still below 100. Consequently,
this option was deemed ineffective to
mitigate the risks of dinoseb use.
• Lower Application Rates. The Agency
also calculated comparative MOS values
for low dinoseb application rates (0.625
pounds active ingredient per acre, as
directed by the label for some fungicidal
uses) versus high application rates (9 to
12 pounds per acre, as recommended by
labels for certain herbicidal uses). MOS
values were comparatively higher for
the lower application rates, but still
well below 100 and therefore
unacceptable.
18
EPA JOURNAL
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• Gender-Based Restrictions. EPA
considered a number of gender-based
restrictions to reduce the risks of birth
defects associated with exposure to
dinoseb. Among other things, the
Agency considered label changes to
prohibit women of childbearing age
from mixing, applying, or handling
dinoseb in any way, or to alert pregnant
women to the risks of dinoseb exposure.
For the purposes of risk management,
the impact of such restrictions is limited
to direct occupational exposures to
dinoseb. As a practical matter,
gender-based restrictions were
considered inadequate to control
secondary exposures to female
bystanders, farmworkers, and others.
Moreover, such restrictions could not
mitigate dinoseb-related risks of male
reproductive effects or acute toxicity.
• Reformulation. Through comparative
MOS calculations, EPA considered the
risk management impacts of
reformulating dinoseb to reduce worker
exposure. None of the available
technologies was found to reduce
dinoseb risks to acceptable levels for
workers performing the various tasks
involved in dinoseb application.
Suspension and Cancellation
Initiatives
In the case of dinoseb, EPA's risk
assessment and risk/benefit balancing
processes led the Agency to conclude
that the risks associated with registered
uses of the pesticide could not be
reduced to reasonable levels by any
means short of immediately removing
the pesticide from the marketplace. For
all crops and use sites, based on all
available risk data and benefits
information, the risks of continued use
of dinoseb were deemed to outweigh the
benefits—not only in the long term, but
also during the interval of time required
to conduct "ordinary" suspension and
cancellation hearings under FIFKA.
Thus, the Agency opted for the most
drastic remedial option available under
FIFRA: emergency suspension calling an
immediate halt to the sale and use of a
pesticide while cancellation proceedings
are conducted, n
Editor's note.: The dinoseb case, ivhich
is iist.'d for illustration purposes in 1/iis
articlf,1, is trurcd only up to the point of
EPA's October 7, 1986, aincdJiition and
emergency suspension notices.
Subsequent developments in the.
dinoseb proceedings are beyond the
scope of the article.
(Flagstad is an assistant editor of EPA
Journal.]
Applying dinoseb in Skagit County,
Washington. Making decisions on
regulating pesticides is an example ot
the risk management process at EPA.
NOVEMBER 1987
-------
Risk Communication:
Informing Public Opinion
by Milton Russell
Scientific risk assessments were not
enshrined in the 200-year-old
Constitution and Bill of Rights
celebrated this year; the guiding force of
the will of the people was. The
institutions that have evolved from this
constitutional base assure that when it
comes to protecting health and the
environment, it is public:, not expert,
opinion that counts. On reflection, few
would have it tiny other way.
Yet, for those schooled in science and
in the rationalistic utilitarian
underpinnings of public: policy,
frustrations abound when it conies to
the way public opinion regards
environmental risks and drives
environmental protection,
Some risks an; large, .sometimes
frighteningly large;, and others small,
sometimes vanishingly small. This is so
whether they are placed on the
measuring rod of total population life
expectancy or on that of the probability
of premature death for small numbers of
exposed people. The same holds true of
non-fatal disease and ecological harm.
At least this is what available scientific
evidence suggests.
Given limited resources, those who
"hold these (rationalistic, utilitarian)
truths to be self-evident" would have
the nation remedy the most severe risks
first, leaving the others to later, or
maybe, if small enough, to never. But
the political system sometimes sends
different orders, and the behavior of
individuals in everyday life often does
not comport with this view.
For example, there are toxic waste
dumps where on all evidence risks are
minimal. Yet, the presence of such
dumps can lead to numbing anxiety on
the part of some, to loss of property
values, and to disruption of
communities. Elsewhere, facilities to
dispose safely of similar wastes may be
resisted by all means possible, including
threats of civil disobedience. And at the
same time, individuals may show little
concern for hazardous products in
ordinary commerce, resist efforts to
protect wetlands vital to ecological
integrity, not choose to test their homes
for naturally occurring radon, and
ignore safe-use labels for pesticides in
home use. Examples of hysteria in the
face of apparently trivial risks and of
apathy before apparently serious ones
form an unsettling litany to risk
managers.
It is also a depressing litany, because
the practical result is a pattern of
national expenditures and of individual
behavior that leaves the country poorer,
sicker, and less ecologically secure than
it could be. This is surely an outcome
no one could knowingly choose. Or
could they?
Research has demonstrated that it is
simplistic to believe that people have
only one goal in protecting the
environment—to reduce calculated risk.
They are also concerned about the
physical characteristics of the risk, its
source, how it is distributed, and
whether it is fairly imposed upon them.
They also have a healthy skepticism
about the certainty of those risk
calculations, and a gnawing anxiety
about what future evidence may bring.
Taking the complex of values that real
people bring to decisions and opinions,
they mciy well choose to be "poorer,
sicker, and less ecologically secure than
they could be," at least as measured
against expert opinion. And tellingly,
our system of government gives them
the right to make that call.
But to make this judgment wisely
requires that individuals know what
experts' estimates of the risks are, what
it would cost in terms qf their other
values to reduce them, and how certain
and free of bias all of this is. Mostly
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"When it ironies to protecting health and the environment, it is public, not expert, opinion that counts."—Milton Russell.
'
EPA JOURNAL
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illusory scientific precision is not
needed, but a sense of "big." "medium,"
"small." or "infinitesimal" is.
The challenge of risk communication
is to provide this information in ways
that it can be incorporated in the views
of common citizens who have little time
or patience for arcane scientific
discourse.
Success in risk communication is not
to be measured by whether the public:
chooses the set of outcomes that
minimizes risk as estimated by the
experts, It is achieved instead when
those outcomes are knowingly chosen
by a well-informed public.
Thomas Jefferson said it best:
I know no safe depository of the
ultimate powers of the society but
the people themselves; and if we
think them not enlightened enough
to exercise their control with a
wholesome discretion, the remedy
is not to take it from them, but to
inform their discretion.
•Two hundred years of constitutional
history has left those ultimate powers
with the people, not the environmental
experts, so one part of Jefferson's vision
has been realized.
The evidence is that the other hasn't.
Communicating environmental risk is a
formidable, continuing task whose
effective pursuit is only now beginning
to emerge from research. Practice lags
still further behind.
Rather than bemoaning the views of
the public when it comes to risks,
environmental professionals could
better look to providing information in a
usable form that might "inform their
discretion."
And their frustrations will be relieved
as they come to understand that values
embodied in environmental judgments
are richer and more complex than those
encapsulated in technical estimates of
risk. LJ
(Dr. Russell holds joint appointments cit
Oak Ridge National Laboratory as c;
Senior Economist and at the (Jm'versify
of Tennessee as Professor of Economics
arid Senior Fellow in flu; Energy,
Environment, cmd Resources Center rind
in the Waste Management Institute.
Until March (987, he was EPA's
Assistant Administrator for Policy,
Planning, and Evaluation.)
Risk Communication:
Facing Public Outrage
by Peter M. Sandman
I
f you make a list of environmental
risks in order of how many people
they kill each year, then list them again
in order of how alarming they are to the
general public, the two lists will be very
different. The first list will also be very
debatable, of course; we don't really
know how many deaths are attributable
to, say, geological radon or toxic wastes.
But we do know enough to be nearly
certain that radon kills more Americans
each year than all our Superfund sites
combined. Yet, as Milton Russell points
out (see proceeding article), millions
who choose not to test their homes for
radon are deeply worried about toxic
wastes. The conclusion is inescapable:
the risks that kill you are not
necessarily the risks that anger and
frighten you.
To bridge the gap between the two,
risk managers in government and
industry have started turning to risk
communication. They want help
convincing the public that one part per
million of dimethylmeatloaf in the air or
water may not be such a serious hazard
after all. Sometimes they want this help
even when one part per million of
dimethylmeatloaf is a serious hazard,
hoping that clever risk communication
can somehow replace effective risk
management. Hut often the best
evidence suggests that the
dimethylmeatloaf really does endanger
our health less than, say, eating peanut
butter (not to mention the really big
hazards, like cigarette smoking). Can
risk communication get people to ease
off on the dimethylmeatloaf and worry
instead about their peanut butter
consumption?
No. What risk communication can do
is help risk managers understand why
the public properly takes
dimethylmeatloaf more seriously than
peanut butter. This understanding, in
turn, can lead to changes in
dimethylmeatloaf policy that will help
bring the public: and expert assessments
of the risk c;loser together.
The core problem is a definition. To
the experts, risk means expected annual
mortality. But to the public (and even
the experts when they go home at
night), risk means much more than that.
Let's redefine terms. Call the death rate
(what the experts mean by risk)
"hazard." Call all the other factors.
collectively, "outrage." Risk, then, is the
sum of hazard and outrage. The public
pays too little attention to hazard: the
experts pay absolutely no attention to
outrage. Not surprisingly, they rank
risks differently.
Risk perception scholars have
identified more than 20 "outrage
factors." Here are a few of the main
ones:
• Vbluntariness: A voluntary risk is
much more acceptable to people than a
coerced risk, because it generates no
outrage. Consider the difference
between getting pushed down a
mountain on slippery sticks and
deciding to go skiing,
• Control: Almost everybody feels safer
driving than riding shotgun. When
prevention and mitigation are in the
individual's hands, the risk (though not
the hazard) is much lower than when
they are in the hands of a government
agency.
• Fairness: People who must endure
greater risks than their neighbors.
without access to greater benefits, are
naturally outraged—especially if the
rationale for so burdening them looks
more like politics than science. Clreater
outrage, of course, means greater risk.
• Process: Does the agency come across
as trustworthy or dishonest, concerned
or arrogant? Does it tell the community
what's going on before the real
decisions are made7 Does it listen and
respond to community concerns?
• Morality: American society has
decided over the last two decades that
pollution isn't just harmful it's evil.
But talking about cost-risk tradeoffs
sounds very callous when the risk is
morally relevant. Imagine a police chief
insisting that an occasional
child-molester is an "acceptable risk."
• Familiarity: Exotic, high-tech
facilities provoke more outrage than
NOVEMBER 1987
21
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People often display less concern about
risks from voluntary activities, such as
skiing or smoking, than from equally
h.'i/ttrrious involuntary exposures, such
as from chemicals in food or in other
products.
familiar risks (your home, your car, your
jar of peanut butter).
• Memorability: A memorable
accident—Love Claiial, Bhopal, Times
licai:h makes tin; risk easier to
imagine, ami (bus (as we have defined
the term) more risky. A potent
symbol—the 55-gallon drum—can do
the same thing.
• Dread: Some illnesses are more
dreaded than others; compare AIDS and
cancer with, say, emphysema. The long
latency of most cancers and the
undetectability of most carcinogens add
to the dread.
• Diffusion in time and space: Hazard
A kills 50 anonymous people a year
across the country. Hazard B has one
chance in 10 of wiping out its
neighborhood of 5,000 people sometime
in the next decade. Risk assessment tells
us the two have the same expected
annual mortality: 50. "Outrage
assessment" tells us A is probably
acceptable and B is certainly not.
These "outrage factors" are not
distortions in the public's perception of
risk. Rather, they are intrinsic parts of
what we mean by risk. They explain
why people worry more about
Superfund sites than geological radon,
more about industrial emissions of
dimethylmeatloaf than aflatoxin in
peanut butter.
There is a peculiar paradox here.
Many risk experts resist the pressure to
consider outrage in making risk
management decisions: they insist that
"the data" alone, not the "irrational"
public, should determine policy. But we
have two decades of data indicating that
voluntariness, control, fairness, and the
rest are important components of our
society's definition of risk. When a risk
manager continues to ignore these
factors—and continues to be surprised
by the public's response of outrage—it
is worth asking just whose behavior is
irrational.
The solution is implicit in this
reframing of the problem. Since the
public responds more to outrage than to
hazard, risk managers must work to
make serious hazards more outrageous,
and modest hazards less outrageous.
Recent campaigns against drunk driving
and sidestream cigarette smoke provide
two models of successful efforts to
increase public concern about serious
hazards by feeding the outrage.
Similarly, to decrease public concern
about modest hazards, risk managers
must work to diminish the outrage.
When people are treated with fairness
and honesty and respect for their right
to make their own decisions, they are a
lot less likely to overestimate small
hazards. At that point risk
communication can help explain the
hazard. But when people are not treated
with fairness and honesty and respect
for their right to make their own
decisions, there is little risk
communication can do to keep them
from raising hell—regardless of the
extent of the hazard. Most of us
wouldn't have it any other way. a
(Dr. Sandman is Professor of
Environmental Journalism at Rutgers
University, and Director of the
Environmental Communication
Research Program there.)
EPA JOURNAL
-------
Risk Communication:
Getting Ready for 'Right-to-Know*
by Charles L. Elkins
"We are drowning in information and
starved for knowledge." —John Naisbitt.
Megatrends
During the next two yours, a tidal
wave of new information on
hazardous chemicals will wash over
thousands of communities across the
United States. The "wave" will consist
of reports to the public on the amount
of hazardous chemicals stored in and
released to the air, water, and soil of
those communities—reports required by
the Emergency Planning and
Community Right-to-Know Act of 19B6
(Title III of the Superfund Amendments
and Reauthori/.ution Act of
1986).
The Community Right-to-Know law is
an exciting new approach to
environmental protection. It is based on
the belief that the more information
citizens have about environmental
conditions in their communities, the
better equipped they will be to ensure
their own protection from unacceptable
risks to their health and safety. The law
requires disclosure by industry of both
the presence and release.into the
environment—including both accidental
and "routine" releases—of hazardous
substances. The information will be
available not only to government
regulators, but also to the people most
directly affected—the residents of the
communities where: the substances are
located,
From FPA's point of view, Title III
presents both great opportunities and
great challenges. Its promise lies in the
wealth of new data on levels and
sources of hazardous substances in the
environment that the law eventually
will provide. As the program matures
and the data become more and more
reliable, information from the Title 111
reports could become the "front end" of
the Agency's toxic: substances and other
regulatory programs. Title III data could
help EPA, as well as state and local
authorities, set regulatory and
enforcement priorities to control
hazardous substances in all
environmental media—air, water, and
soil,
The law also could become u driving
force for the development of new
industrial processes and techniques to
eliminate hazardous wastes at their
source—before they are produced and
either released into the environment or
trucked away for expensive, and not
always effective, treatment and disposal.
But the promise of the community
right-to-know information over the long
run is equalled by the problems it could
cause, if not properly understood and
used, in the short run. Except in a
handful of states that already have
community right-to-know laws,
businesses have little or no experience
in reporting this kind of data.
Consequently some reports—especially
the reports of annual "routine"
emissions of toxic: chemicals required
by Section 313 of Title 111—are likely to
be very rough estimates of actual
releases. The value of the emissions
data in the first years of the program
probably will be limited to helping EPA
and other authorities identify potential
"hot spots"—areas with apparently
high levels of toxic: emissions—tor
careful monitoring and evaluation to
determine if an environmental hazard
may be present that requires immediate
attention.
Despite the limited reliability and
value of some Title III reports in the
early years, however, the information
collected from more than one million
industrial facilities, farms, small
businesses, and other chemical users
around the nation will be immediately
available to the public:. The Community
Right-to-Know law requires the states in
which the facilities are located to
release the information to anyone who
requests it. either in printed form or—in
the case of the annual emissions reports
by EPA- - on a national computerized
database called the Toxic: Release
Inventory (TR11. Title Ill's requirements
for reporting on the storage and
accidental release of hazardous
chemicals are already in effect: the first
round of annual emissions reports must
be submitted by July 1. 1988. HI'A
expects the national database to be
ready for public: access by the spring of
1989.
How prepared are America's
communities to receive, understand.
and act on this unprecedented deluge of
information about hazardous chemicals?
That question has been a central
concern to Kl'A since the law was
passed. And the answer, unfortunately,
seems to be: not very.
Public: opinion polls such as those
taken by the Roper Organization during
the past few years show that most
Americans believe that toxic: chemicals
can be found in the air. water, and soil
in the United States-—but not in their
own neighborhoods. Except in
industrialized regions or arras where
hazardous substances arc; knrwn to have
been dumped or buried the
"Superfund" sites toxic: chemicals
seem to be, tor most Americans,
"somebody else's" problem.
Hut .some people who hold this view
could be in for a surprise as the lirsl
Title III reports become public;
knowledge -especially if they indicate
that substantial amounts of hazardous
chemicals arc; stored and routinely
released into the environment in their
particular neighborhoods.
The routine emissions reports, which
will show estimated or actual toxic
releases on an annual basis, could be
especially alarming.
Continued on next puge
NOVEMBER 1987
-------
How prepared are America's
communities to receive,
understand, and act on this
unprecedented deluge of
information about hazardous
chemicals?
For example, a newspaper article
based on the Section 313 reports might
look like this:
Local Plant Dumps Toxic
Chemicals in Crystal River
The ABC Manufacturing Co. in
downtown River City dumped
more than 200 tons of toxic
chemicals, including several
cancer-causing substances, into the
Crystal River last year, according
to reports made public yesterday
by the U.S. Environmental
Protection Agency.
The river is the major source of
drinking water for River City and
most of surrounding Utopia County.
The reports also show that ABC,
a leading producer of
chrome-plated industrial widgets,
released nearly 50 tons of toxins
into River City's air in 1987, and
sent another 300 tons of
potentially poisonous material to
the Utopia waste-treatment plant
for disposal.
Last year, the plant reported to
EPA that it stores more than 1,000
tons of hazardous substances
within a few blocks of River City
High School. On three different
occasions over the past six
months, plant accidents have
released clouds of hazardous and
toxic chemicals into the
surrounding neighborhoods.
Now, if you were a resident of River
City, what would your reaction be?
Outrage? Skepticism? Concern for your
family's well-being? A heated phone
call to the Mayor or the company
president, demanding an explanation or
an immediate shut-down of the plant?
The question is not altogether
hypothetical. Articles similar to this
could begin popping up in the news
media around the country as the Title
III reports become available. Such news
stories, based on accidental release or
annual missions reports of questionable
24
accuracy and written out of context,
could be extremely misleading. And
even accurate reports, by themselves,
simply will not provide enough
information for citizens or government
officials to reach informed conclusions
about whether hazardous chemicals
actually pose a serious health risk in
their communities.
In some instances, in fact, public
concern over Title III reports could be
entirely justified; toxic emissions into
the air, water, or soil, for example,
could endanger the health of citizens or
the welfare of the environment.
The key word, however, is "could."
The simple fact that toxic chemicals are
released doesn't necessarily mean that
public health and environmental quality
are threatened. The fact that Company A
says it released 50 tons of chemical X
while Company B reports releasing 100
tons of chemical Y doesn't necessarily
mean that Company B's emissions are
twice as big a problem as Company A's.
Much more than raw, unverified release
information is needed to determine the
risk in a given situation. And that's
where the Community Right-to-Know
law creates a major challenge for those
whose job it is to assess and manage
environmental risks to human health.
EPA management believes that the
Agency, along with industry,
environmental groups, and state and
local governments, has a responsibility
to help the public understand the
significance of hazardous substances in
the environment. We must do more than
simply collect and verify the
information and make it available.
Under Sections 301-303 of Title III,
states and localities have established
state emergency response commissions
and local emergency planning
committees to receive and handle
community right-to-know information
required by the law. Section 302
requires facilities (manufacturing plants,
distributors, farmers—anyone storing
more than a specified quantity of any of
406 chemicals listed as "extremely
hazardous" by EPA) to report the
presence of those chemicals to their
local emergency planning commission.
Thousands of facilities will be reporting
this year. They must also report
accidental releases of hazardous
chemicals under Section 304, provide
on-site inventories of hazardous
chemicals under Sections 311 and 312,
and provide other T:hemical-specific
information.
The local committees are required to
make the information available to the
public and to develop emergency plans
in the event of a chemical accident. EPA
is working closely with the state
commissions and local committees to
provide guidance for interpreting and
understanding the meaning of all of the
information reported under Title III.
Communicating information on the
risks posed by hazardous chemicals,
however—in toxic waste dumps, in
consumer products, or in the air, water,
and soil from industrial emissions—is
not easy. Different perceptions of risk,
conflicts between new information and
existing beliefs, and mistrust of the
people or institutions doing the
communicating can be extremely
difficult to overcome.
To meet these communications
challenges, EPA is developing a number
of programs to help inform and educate
community leaders, the news media,
and citizens about the relationship
between toxic substances in the
environment and human health. For
example, in keeping with the
Right-to-Know law's emphasis on
community awareness and
decision-making, EPA, through its
regional offices around the country, is
attempting to provide states—and
ultimately local health agencies and
other public officials—with technical
tools and training to help them evaluate
public exposure to toxic chemicals. This
is intended to help them estimate the
degree to which toxic releases may pose
a threat to their state's or community's
well-being; rank the problems in order
EPA JOURNAL
-------
Under Right-to-Know provisions in a
new law, people will receive a lot of
information about discharges of
hazardous chemicals in their
communities.
James Douglas. Woo&fm Cr
NOVEMBER 1987
of priority; and then make informed
choices about courses of action based on
the values and needs of their citi/ens.
By itself, hazardous release data from
the Title III reports means very little in
terms of human health. Along with
emissions information, at least two
other sets of data are needed to -.et
priorities for managing risk. They an; .1
chemical's toxicity—its ability to cause
adverse health elfei.ts .it specific.
concentrations—and the degree of
public exposure to the chemical—in air,
water, or food. Some toxicity
information is already available on
many of the chemicals and chemical
categories whose presence and release
must be reported under Title 111. KPA
will make that information available to
state and local officials and the public
as quickly as possible. At the same time.
EPA plans to step up its efforts to define
the toxicity of other substances which
have not yet been thoroughly evaluated.
Determining the level of exposure to
particular chemicals is. in some ways,
even more difficult than assessing their
toxicity. One method is to take
measurements at various points near a
known or suspected emissions SOUK e,
and then relate the results to the si/.e of
tin; local population. This kind of
monitoring, however, is expensive and
time-consuming. Main measurements
must be taken because exposure levels
can vary under different atmospheric:
conditions or at different times of the
year.
Another method of determining
exposure involves computer modeling.
Here sophisticated techniques are
employed to relate reported or measured
emissions to atmospheric:.
climatological, demographic,
geographic:, and other data in order to
predict a population's potential
exposure to a given chemical. HI'A has
been working for many years to
develop, refim1. and expand these
computer modeling programs. OIK;
svstem developed by KP.Vs Office of
-------
Determining the level of
exposure to particular
chemicals is, in some ways,
even more difficult than
assessing their toxicity.
Toxic Substances, the Graphical
Exposure Modeling Svstem |C,KMS|,
integrates maitv other modeling
programs in .1 single "user-friendly"
p.ii kagi-. < oinplctf with graphic s .mil
mapping capabilities. (IKMS. already in
use throughout KI'A. in 21 .stales, and in
two European i (iiintries. shows promise;
for application to the toxic emissions
ii.it,i espec i.illy after the data have
been evaluated and steps taken to
inipiove their reliability. \Ve are now
considering ways that CKMS |or a
similar svstem) might be used, at least
initially, as a broad si reening tool to
identify areas that might warrant closer
scrutiny by state and local officials.
I,ike emissions data, chemical toxic itv
information, exposure estimates, and
risk evaluations are subject to many
uncertainties. Hut by making technical
tools like GEMS and chemical toxicity
information available to state ,iud local
authorities, and bv conducting a public
eilm alicm effort to inform the- Americ an
people about the relationship between
toxic chemicals and human health. HI'A
hopes that public c oncern and attention
will begin to focus on the particular
i lienin al ba/.ards that pose the most
serious threats.
Armed with the inloi niation required
by the Community Kight-to-Know law.
inc.hiding the' emergem v preparedness
plans required bv sei tions 302 and 303
.mil bolstered by a better public
understanding of the significance ol
toxic, chemicals in tin; environment,
Ameht a's i ninnuinities should be' much
better prepared than thev ha\'e been in
the past to make! informed, reasoned
risk management decisions that will
best reflect the needs and values of their
citi/.ens. : i
(HJkms is Director of KP/Vs Olfice ol
Toxic Substances.!
Who Must Report?
Title III. or the Emergency
Planning and Community
Right-to-Knou Act of 1981),
requires a variety of reports to
citi/.en.s on the chemicals being
produced, used, or stored in their
communities—including releases
of hazardous chemicals into the
environment.
Here is a brief summary of Title
III reporting requirements:
• All facilities that have on their
premises specified quantities of
chemicals designated under Title
III as "extremely hazardous
substances" must cooperate with
state ami local planning officials in
preparing comprehensive
emergency plans (Sections 302 and
3031.
• Facilities that produce, use. or
store specified haxardous
substances must report accidental
releases of those substances above
certain quantities to state; and local
response officials (Sec.lion ;i()4|.
• All facilities that are required to
prepare Material Safety Data
Sheets (MSDSs) must make them
available to state and Inc al
authorities. They must also report
to local and state officials on
inventories (including locations) of
chemicals on their premises for
which MSDSs exist (Sections 311
and 312).
• Some facilities must lile annual
reports on industrial release's of
toxic chemicals into the
environment. A facility is covered
bv this requirement if it is a
manufacturing facility in Standard
Industrial Classification (SIC)
codes 20 through 35): has ten or
more full-time employees: and
either used more than 10.000
pounds of one of 32!) chemicals
and chemical categories during the
previous year, or manufactured or
processed more than 75.001)
pounds of a listed chemical during
the year. (The; reporting threshold
for manufacturing and processing
drops to 50.000 pounds tor reports
covering 1988 and to 25.000
pounds for 1989 and thereafter).
(Section 313)
To obtain more information
about reporting requirements
under Title III. call EP.Vs Title III
Hotline. 800-535-0202
•
EPA JOURNAL
-------
The possibility of health-threatening radon concentrations in some homes presents EPA with a major ch:ilk;ntjo to
communicate information that will help people make their own risk management decisions.
Risk Communication:
Getting Out the Message
about Radon
by Ann Fisher
EPA cannot use its traditional
regulatory tools for some
environmental risks. Instead, the
Agency has to explain the risks that
people face so that, as individuals, they
can make their own risk management
decisions. Radon is one of these cases.
The radon example illustrates many of
the difficulties that individuals tact! in
dealing with risk and that agencies,
including EPA, have in communicating
effectively about risks.
EPA's Office of Radiation Programs
estimates that radon causes 5,000 to
20.000 lung cancer deaths each year in
the United States. Radon is a colorless,
odorless gas that seeps into homes from
the soil beneath them and sometimes
from the water coming out of faucets.
EPA has no regulatory authority over
NOVEMBER 1987
-------
People can be expected to
take action only if they know
about their risks and what
they can do to protect
themselves.
radon in homes, so the Agency's
program has relied primarily on a
strategy that encourages voluntary risk
reductions by individual homeowners.
The radon program is one of several
nonregulatory EPA programs that are
encouraging voluntary actions to reduce
risk.
But people can be expected to take
action only if they know about their
risks and what they can do to protect
themselves. In the case of radon, we
must alert people to the possibility that
they may be at risk, and the only way
they can find out is to have their homes
tested. People also need to know how to
test their homes and what they can do
to reduce risk if test results show
elevated radon levels.
It is not always clear what strategy
will be best for communicating such
information. For instance, the state of
Maine distributed pamphlets about
radon to people who had their homes
tested. Most of these homes had radon
levels below those where EPA
recommends taking action, and a
follow-up showed that many residents
perceived their risk to be even lower.
Paradoxically, nearly half of them had
done something to reduce their radon
exposures. However, just as many
people with low radon levels were
taking remedial stops as were these with
houses having high radon levels. This
means that some people were spending
money to reduce very low risks, while
others were not doing anything about
very high risks from radon.
New Jersey feared that its Department
of Environmental Protection would be
overwhelmed by requests for
information and assistance because of
extensive media coverage about radon
in the Reading Prong (which includes
part of New Jersey). However, a study
there showed that very few people had
even considered testing; apathy was
much more of a problem than undue
concern.
EPA has faced real difficulties in
attempting to reduce radon's health
threat. The Agency lacks regulatory
authority in this area, and evidence
about the effectiveness of existing
information programs has been
discouraging. The urgency of the public
health threat led to EPA's accelerated
development of a booklet called A
Citizen's Guide to Radon (OPA-86-004).
This publication was designed to raise
awareness and explain how people
could test their homes. EPA also
published three booklets about
mitigating risk: Radon Reduction
Methods (OPA-87-010), for the general
user; Radon Reduction Techniques /or
Detached Houses: Technical Guidance
(EPA/625/5-86/019), for those who want
more detail; and Removal of Radon
from Household Water (OPA-87-011),
for the relatively small share of homes
where elevated radon comes from water.
Recognizing the uncertainties about
how to set up an effective information
program, staff at EPA headquarters,
several EPA regional offices, and state
environmental agencies have been
evaluating different approaches for
communicating about radon risk. For a
monitoring study in New York, EPA
developed four experimental booklets
that express radon risk in different
ways. Along with their home's radon
test results, homeowners participating
in the study were sent one of these
booklets, an EPA's Citizen's Guide, or a
single-page fact sheet.
The homeowners are being
interviewed both before and after
receiving the risk information. These
"before and after" interviews are
intended to assess what people know
about radon, their perceived radon risk,
their desire for additional information,
and ultimately their decisions about
reducing their radon exposure.
Preliminary results show that the
Citizen's Guide performs reasonably
well, but can be improved. The fact
sheet caused undue concern, and no
longer is being used. The final data set
concerning these homeowners will be
gathered next summer and will be used
in revising the Citizen's Guide.
A study in Maryland is examining
how to motivate people to test for radon
in the first place. (Homeowners in the
New York study had been contacted by
the state, which sent free monitors to
those who agreed to participate.) A
multi-pronged approach is being tested
in two cities. It will use posters, public
service announcements on radio and
television, and leaflets distributed along
with utility bills and in doctors' offices,
in addition to the official EPA booklets
listed above. One of the cities also will
have intensive public outreach, with
slides and script for use by community
organizations. A third city will serve as
a control, with no information program.
Interviews before the information
program and afterward will measure
increases in awareness of radon and its
risks, whether people decide to have
their homes tested, and their plans for
mitigation. The results should indicate
how effective it is to have multiple
sources communicating about risk and
reaching people multiple times.
These studies are focused specifically
on radon, and their results will help
EPA improve its radon information
program as a way to reduce the health
risks from this potentially dangerous
gas. At the same time, the results will
guide other information activities that
are designed to reduce risk through
voluntary action on an individual basis
as an alternative to regulation, a
(Fisher is a senior economist and directs
risk communication projects in EPA's
Office of Policy Analysis.)
28
EPA JOURNAL
-------
On the Firing Line:
The Challenge of
Environmental Risk in
Region 8
by David Wann
The telephone rings often in EPA
toxicologist Suzanne Wuerthele's
office in Denver. This time it's a citizen
whose house was recently sprayed with
the pesticide chlordane, and who has
heard on the news that chlordane's use
will be restricted and phased out.
"The people who call me often want
yes/no answers: will substance X give
me cancer or won't it?" Suzanne said.
"The problem is, only God can give you
zero or 100 percent probability. We try
to provide the public something in
between."
The caller about chlordane is
one voice among many:
"Would you drink this
water?"
"My constituents demand
clean, healthy air."
"How can you justify closing
our plant when 300 jobs will
be lost?"
"We're people, not just
numbers."
Residence in Mill Creek, IV with
a smokestack from a fiv
Minerals Company smelter in
background. Wastes from tl
have posod a scientific and pu
information challenge to EPA R
with relocation of the towr iinu
familes as the option c
-------
"Only God can give you zero
or 100 percent probability. We
try to provide the public
something in
between."—Suzanne
Wuerthele.
The common thread running through
these concerns is risk, particularly risk
which happens involuntarily. At the
heart of environmental decision-making
at EPA's regional level is the stark
reality of actual people and their needs,
side-by-side with an almost infinite
variety of circumstances: each site or
occurrence is unique.
When risk assessments are made at a
national level to set guidelines, create
legislation, or make management
decisions on a national scale, those
"five cancers in a population of a
million over a 70-year period of
exposure" are hypothetical and
anonymous. But when applied to
real-world decision-making, human
faces begin to emerge from the midst of
the numbers.
As Region 8 Deputy Regional
Administrator Alexandra Smith puts it,
"Here in the Regions is where the
rubber hits the road." Decisions have to
be made as quickly as possible, yet
often without absolute scientific
certainty. As EPA toxicologist Jim Baker
explained, "Sometimes we have only
two data points, sometimes 200, but we
never seem to have as many as we'd like
to have."
Inevitably, when the issue is a hot
one, the scientific, probabilistic nature
of risk assessment tends to float like a
tiny boat on a sea of human emotions.
One such issue is the proposed
incineration of mixed radioactive and
hazardous wastes at the Department of
Energy's Rocky Flats plant just north of
Denver. Nat Miullo, EPA coordinator on
the project, explained, "Three separate
risk assessments (including the
Department of Energy's assessment) are
now being juggled by the public. One of
them, generated by a coalition of
scientists who live near the plant,
disputes the point assessment made by
the Centers for Disease Control (CDC)
and the Colorado Department of Health
(CDH), alleging that CDH's analysis
underestimates risk by 160 billion times.
But the coalition's assessment is
based on a worst-case scenario which
assumes that a 'domino effect' of nearly
impossible events will occur at the same
time."
Miullo continued, "The problem with
this sort of assessment is that the word
'probability'—used in a statistical
context—becomes a 'strong possibility' in
the mind of the public. Misperception
becomes reality." He emphasized the
absolute importance of starting with
reasonable assumptions.
"The coordination among the primary
players—in this case EPA, other federal
agencies, the State of Colorado, local
governments, and citizens—is crucial in
the beginning stages of a risk
assessment. We need to know where the
data are coming from—how they are
gathered and how they are reported.
And we have to make sure the right
questions are being asked: How much
air does the average person really
breathe? What are the meteorological
conditions? What is the probability of a
worker tripping over a monkey wrench
and somehow flipping the wrong
switch?"
In the tiny mining town of Mill Creek,
Montana—located near the Anaconda
Minerals Company copper smelter—one
of the more critical risk assessment
variables turned out to be, "How much
soil does the typical child ingest over
the course of a year's play?"
Between 1884 and 1980, Anaconda
produced more than 185 million cubic
yards of tailings as well as other wastes
such as flue dust. These wastes
contained not only arsenic, which at
low levels poses a clear-cut risk for
producing skin and lung cancer, but
also lead, cadmium, copper, and zinc.
The possible interaction of these metals
and their cumulative health effects
posed a scientific challenge to Region 8
personnel and EPA contractors.
The fundamental question which had
to be answered was, "How many are
exposed to how much health risk from
which interacting contaminants?"
Because the area is extremely dusty,
Mill Creek's houses and furniture had
become contaminated, and because of
the inevitability of re-contamination, the
houses were judged by EPA to be
uncleanable.
When lab tests revealed elevated
levels of arsenic in the urine of resident
pre-school children, it was indisputable
that something had to be done. After
cost estimates for the removal of
millions of tons of soil were weighed
against costs of relocating the residents
of Mill Creek, relocation emerged as the
best option. The management decision
was a clear one, but only after an
30
EPA JOURNAL
-------
"in-the-trenches" assessment had been
carefully performed.
Jim Baker explained. "Two apparently
identical mining waste piles in different
towns may post completely different
risks, because heavy metals in one pile
are in a soluble form, while those in the
other are not. Or one of the piles may be
located near a school or over a
groundwater source. Citizen response is
also highly variable. Old-timers in a
mining town which is being considered
as a Superfund site may regard the
tailings piles as a bit of Western history,
something they played on as children.
They may bitterly resent the state and
federal "interference," which they feel
will lower their property values.
Baker added that each geographical
area has its own unique characteristics,
which make a generic assessment
impossible. "In the West, for example,
we have arid conditions, high altitude,
and a lot of mining and agriculture. On
362 days of the year, a certain lazy
prairie steam may be nearly a dry
creekbed, but the other three days a year
it's 10 feet high and eroding everything
in its path."
Exposure assessments and risk
characterization are areas in which the
regions' involvement is indispensable.
Typically, regional risk assessors
overlay site-specific data on generic
dose-response data which have been
generated by EPA labs, National
Institute of Occupational Safety and
Health labs, or CDC to arrive at
an assessment for a particular site.
This approach was taken at an
unorthodox Superfund site in Denver
consisting of 44 separate properties
contaminated by wastes from radium,
vanadium, and uranium processing
operations conducted early in this
century. After an extensive exposure
assessment, the existing risks for the
sites were determined to be small.
However, if the material is ever
disturbed or if buildings are built and
occupied on top of the tailings, those
calculated risks will skyrocket. In this
case, risks to future populations were
heavily considered in decision-making.
Removal and long-term isolation of the
material has been proposed as the most
protective solution, since radium has a
half-life of 1,600 years, and on-site
isolation of the wastes was judged to be
highly uncertain in a developing urban
area.
In Minot, North Dakota, in April
1987, EPA's Emergency Response
Branch did not have the opportunity to
deliberate over future risks. A
warehouse stacked to the roof with
agricultural chemicals in anticipation of
the coming growing season caught fire,
raging for four hours and then
smoldering for the next couple of days.
Floyd Nichols, the emergency
response on-scene coordinator, recalls
that "Nobody got any sleep for about
four days" while an inter-agency team
grappled with finding the best solution.
Because the receiving waterway, the
Souris River, flows into Canada, the
problem had international implications.
EPA cooperated with the Manitoba
government, the U.S. Coast Guard,
OSHA, the State of North Dakota, the
responsible parties, and others to bring
about a swift, effective solution.
Nichols said, "Sometimes our actions
had to be by trial and error as we were
laying out an action plan, but we
reached consensus on a containment
and cleanup procedure within two days,
with the responsible party agreeing to
pay the bill."
He added that one of the concerns in
coming up with a solution was making
sure they weren't doing more than they
had to. "We were very much aware of
the fact that over the next several days
we'd be authorizing the expenditure of
two or three million dollars."
The response to the Minot fire was
greatly enhanced by the work of an EPA
bioassay team which happened to be in
North Dakota at the time, and was
dispatched to Minot. Using
ceriodaphnia (a tiny, shrimp-like
bioindicator), fathead minnow, and
algae tests, the aquatic toxicologists
pinpointed the degree of toxicity in
water which had been pumped into
temporary holding tanks. They also
trained the State of North Dakota
scientists in bioassay methods which
the state has since used elsewhere.
Bioassay techniques are a valuable
piece of Region 8's strategy to reduce
environmental risk as well as health
risk. Because of the quick, conclusive
results which are possible, bioassays
offer an excellent means of evaluating
entire watersheds. If contamination is
discovered in a river, for example, the
pollution source can be traced back
upstream with short-term bioassays
which give definitive results within
several days.
The need for techniques which
steamline the complexities of risk
assessment is also reflected in the
Integrated Environmental Management
Project (IEMP) which is now underway
in Denver. This project, like its
predecessors in Philadelphia, Baltimore,
and Santa Clara County, California, will
use risk assessment techniques to focus
on the relative risks of local problems,
with heavy participation from local
decision-makers and leaders from
Denver's business, scientific, citizen,
and environmental communities.
Several of the key questions Denver's
IEMP will attempt to answer are:
• Does local perception of the worst
environmental problems correlate with
scientific judgment of the risk?
• Are the various institutions which
oversee pollution reduction
coordinating their efforts effectively?
• How do cancer risks from compounds
studied in the project compare to the
overall risk of cancer in the
metropolitan area?
• Do the relative risks from toxic air
pollutants appear to be greater than the
health risks from abandoned hazardous
waste sites?
The conclusions reached by the
Denver IEMP will help Region 8 and
other EPA regions evaluate and manage
risks. The cross-media and
intergovernmental aspect of the project
is intended to broaden agency
perspectives on risk reduction by
acknowledging two postulates which
keep surfacing in EPA's regions:
"Everything is interconnected" and
"Every place is somebody's backyard."
In the regions, direct contact with the
public as well as with the unique
features of each site characterize risk
decisions. Working "in the trenches"
alongside state and local personnel, it
sometimes seems to EPA scientists,
engineers, and managers as if the
inherent complexities result in "three
steps forward and five backwards." But
while risk assessment can rarely offer
complete certainty on a given issue, it
does help enable another three steps
forward, a
(Wann is a technical writer in the Office
of External Affairs, EPA Region 8.J
NOVEMBER 1987
31
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On the Firing Line:
Risk Management in the
Santa Clara Valley
by Nancy lanni and Keith Hinman
Residents of California's Santa
Clara Valley can look forward to a
better protected environment in the
years ahead, thanks to alert and
concerned local governments and
community leaders, and to KPA's
Integrated Environmental Management
Program (IEMP). The IKMP combines
risk assessment, management, and
communication to help determine the
Valley's environmental goals.
In the late 1970s the area—known us
"Silicon Valley"—was blossoming, under
a booming high-tech economy that
seemed to be free of the air and water
pollution problems common to
smokestack and other heavy industries.
"Silicon Valley" was seen as the
environmentally safe, high-tech
industrial wave of the future.
Then, in 1!)H1, the future was clouded
by discovery of a serious industrial
chemical leak from an underground
storage tank belonging to a San Jose
semi-conductor manufacturer. The tank
was leaking TCA, an industrial solvent.
As concern about this single incident
and its potential impact on ground
water mounted in the news media, other
firms, directed by the Regional Water
Quality Board to investigate their
storage and waste disposal systems,
found hundreds of other fuel and
industrial contamination sites. l)n/,ens
of drinking water wells won; affected.
As the Water Quality Hoard gathered
the samples from the various locations
and detected the different pollutants.
EPA scientists joined in the burgeoning
Valley-wide risk assessment process that
grew in response to public alarm about
contamination of the water supply and
the possibility that drinking the
contaminated water could cause birth
defects. Their role was to try assessing
the levels of contamination and their
potential health impacts, while Santa
Clara County and local municipal
officials joined with citizens and
industry groups to develop new local
ordinances controlling the handling and
storage of hazardous materials. They
were among the first in the country to
respond to a regional pollution risk
assessment with locally developed risk
management regulations governing
hazardous materials.
In 1983, the EPA saw in the Santa
Clara Valley a unique potential
laboratory for experimenting with the
Agency's new iEMP approach. The area
was actively concerned with its
environmental problems, and the
industrial infrastructure and pollution
situation were different from those to
the east, where ground-water
considerations were less related to
industry. When EPA proposed the
project, the local leaders were receptive;
after all, the Valley residents had
already mobilized to deal with their
environmental problems in a
constructive \vay.
EPA hoped to use the risk-based IEMP
approach to foster management
decisions that were more directly linked
to specific local environmental results
than traditional approaches based on
state or federal regulations targeted at a
single medium such as air or water. The
project hoped also to compare a wide
range of environmental problems and
set management priorities, using a
common measure of risk to human
health. From the outset, the project was
conducted through an open process
involving an active dialogue between
the community leaders and federal,
state, and local regulators.
Among the lEMP's major successes
was the integration of state, local, and
federal government agencies into a
common effort, although this was not
one of the project's primary goals. As a
result, even though the IEMP had no
authority to enforce its
recommendations, the implementing
state, county, and regional agencies
involved have taken them seriously. A
number are already in the process of
being implemented, and local funds
have been appropriated to form a new
Santa Clara Valley Toxics Policy
Council to promote consistent policy,
evaluate programs, target issues for
attention, and serve as the unified voice
of the region to state and federal
agencies. This is especially important
because of the large number of local
governments involved.
The Council would continue many of
the positive aspects of the IEMP:
centralized consideration of
environmental issues, an open process
involving the public, and development
of policy by consensus. The key
difference between the Council's future
role and the pre-IEMP days is that the
Council will be an official, permanent
body, marking the transition from a
pilot project to an ongoing program.
On the other hand, one of the
project's ambitious early
goals—obtaining specific scientific
confirmation of the potential risk of
birth defects from toxics in the water
supply—was not achieved. EPA
laboratory tests and epidemiological
studies were unable to generate the
data. Scientific risk assessment could
not, for example, prove that the TCA
from the industrial spill that started it
all would or would not cause birth
defects.
This, in turn, related to another key
IEMP goal, determining whether the
esoteric-seeming techniques of risk
assessment and risk management could
be used as practical management tools.
As it turned out, the sophisticated
analytic approaches did not always fit
local needs for quick, short-term
decisions about beefing up controls or
standards for environmental damage
prevention, nor were the results of such
studies readily understandable to
participants in public hearings. They
found the time required for risk
assessments, cost-effectiveness analysis,
and program evaluation frustrating,
given what they saw as a pressing need
to take action. Some were disappointed
by the complexity of EPA analyses and
the substantial uncertainty surrounding
risk assessment estimates. They had
hoped for simpler and more clear-cut
findings.
Nevertheless, the IEMP has been fairly
successful in combining analysis and
public process to produce practical
proposals for improvements in
environmental management.
EPA JOURNAL
-------
• A major project achievement has been
the communication to local citizens and
leaders of the best available information
on health risks from toxics. As a result,
area officials, community leaders, the
news media, industry, and public:
interest groups, today have a sounder
and more consistent understanding of
the Valley's environmental problems
than they did four years ago. While
there are still debates over whether TCA
causes birth defects and more controls
are needed, the area has moved from
policies driven by frightening
newspaper headlines to more rational
policies based on facts and analysis.
• The IEMP helped place ground-water
contamination in perspective and
refocus a general anxiety about health
risks from ground water into specific
areas where constructive action could
Workers in a high technology industry
in Santa Clara Valley, California. Often
thought to be environmentally clean,
some high-tech firms in the Valley were
linked to ground-water contamination,
which triggered an EPA-local effort to
understand and manage the risks.
be taken in relation to users of small
private wells. It also emphasized the
importance of ground-water protection
and management so that not only health
but potable future water availability is
considered. The project also made
recommendations for improved
ground-water management through
efficient and coordinated prevention.
cleanup, and user-protection programs,
including ground-water protection zones
to restrict activities that threaten
vulnerable resources, and addressing
Valley-wide resource impacts and
health threats while developing the
cleanup policies. Strengthening the
county and local toxics disposal and
storage ordinances was also
recommended.
• As a result of its multi-media
approach, the project also focused
attention on air pollution and forced the
Valley to face up to the way
automobiles were producing smog and
creating growing health risks as ozone
and carbon monoxide levels began to
rise in the area. The California State
Implementation Plan is being reviewed
with these findings in mind, and
improvements in local air pollution
controls are being sought. The project
also recommended that air toxics and
criteria pollutants be simultaneously
considered in future regulatory
development.
Effective management of
environmental toxics cannot take place
unless the people affected are educated
about risks and the trade-offs involved
in controlling them, and are empowered
to make their own decisions. While the
IEMP has been time-consuming, at times
frustrating, and often controversial, it
has done the Santa Clara Valley an
invaluable service. It has moved the
community several steps closer to
understanding and controlling its
environmental destiny, n
(lanni is a member of the San Jose City
Council. She chaired the lEMP's
Intergovernmental Coordinating
Committee. Hinman ivas EPA's Project
Manager for the Santa CJara Valley
IEMP; he is now an Environmental
Specialist in Region 10.J
NOVEMBER 1987
33
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From the Outside:
An Environmentalist's
View
by Ellen Silbergeld
Manufacturing paper. Recent findings that commonly used paper products could possibly contain tiny concentrations of the
toxic chemical dioxin raised questions about how environmental risks in products in wide use can be assessed and managed.
EPA JOURNAL
-------
Risk assessment has become an
increasingly controversial subject in
environmental policy. As process, it
remains inaccessible and hence
unintelligible to many concerned with
environmental issues. To the public,
risk assessment is viewed empirically,
that is, in terms of the results which are
associated with its application. In that
setting, it suffers from the general view,
among the public, that the last decade at
EPA has been characterized by inaction
and evasion except in those areas where
legislation has compelled
decision-making as in the hammer
provisions of Resource Conservation
and Recovery Act (RCRA) and
Superfund. Risk assessment in
connection with regulatory activity
under the Clean Air Act, the Clean
Water Act, or the Toxic Substances
Control Act has certainly not been
associated with a great deal of action or
risk reduction using these statutory
powers. Moreover, risk assessment is
frequently viewed as operationally
coupled with cost/benefit analysis, or
the economic valuation of risk reduction
actions.
Because the public in general, its
doubts confirmed by several recent
court decisions, does not accept an
accountancy approach to environmental
regulation, this joining does not help
the image or acceptability of risk
assessment. Industry, on the other hand,
seems to be increasingly opposed to risk
assessment because of its alleged
extreme conservatism, and because its
use appears to be a relatively inflexible
source of very low regulatory numbers,
which, if ever applied in regulation,
would support extremely stringent
control actions. State authorities are in
many instances unhappy with EPA's
strong endorsement of risk assessment
because of fears as to the resource
requirements necessary to develop,
interpret, and enforce risk
assessment-based regulations. These
resources are not well distributed
through the country; Connecticut's
recent misadventures with
misunderstanding the nature of cancer
risk assessment demonstrates the pitfalls
of uninformed decision-making.
Given this lack of acceptance, it may
be surprising that the issue of risk
assessment is still being discussed. At
its simplest, risk assessment is no more
than a consistent methodology to do
two things: incorporate the results of
experimental toxicology, and develop
estimates of appropriate goals for
regulation or cleanup. It is not clear that
risk assessment can go beyond those
goals. It is, moreover, extremely limited.
Quantitative risk assessment, by which
is meant the process of generating
relatively precise dose: response
information, is presently limited to
assessing the risk of cancer.
All other types of risk are generally
only qualitatively evaluated; in such
arenas, arguments over types of models
and extrapolation assumptions do not
arise. Unfortunately, very little real
consideration of non-cancer endpoints
is undertaken and a kind of
toxicological Gresham's Law operates,
where bad regulatory toxicology drives
out good, and other endpoints—which
may be much more conclusively
demonstrated for a particular
chemical—are neglected in the
argument over quantitative cancer risk
Given this lack of acceptance,
it may be surprising that the
issue of risk assessment is still
being discussed.
assessment. For instance, many years
have been lost debating the carcinogenic
properties and quantitative risk
assessment of formaldehyde and dioxin;
yet these two chemicals have very
clearly identified effects on the immune
system (both), the nervous system
(formaldehyde), and reproduction
(dioxin).
Currently, EPA seems to be sending
mixed messages about risk assessment.
On the one hand, EPA has recently
promulgated Science Advisory
Board-reviewed guidelines for risk
assessment, which represent consensus
scientific opinion as to appropriate
statistical methods and interpretation;
on the other hand, EPA, in specific risk
assessments, inserts so much hesitation
and qualification in the name of
"scientific uncertainty" that it becomes
impossible to determine the Agency's
actual position. It is this kind of
double-dealing with risk assessment—its
methods and results—which keeps the
public from accepting this approach.
Scientifically, the most unfortunate
result of risk assessment as practiced by
EPA is to make assumptions as to
biological mechanisms overly rigid. For
instance, in cancer assessment,
demonstration of initiation properties
such as mutagenesis has become
all-important. Thus, for risk assessment
purposes, chemicals are forced into a
dichotomy of causing mutations or not
(what people frequently refer to as
genotoxic and non-genotoxic or
epigenetic).
This dichotomy is not scientifically
valid. First, chemical carcinogenesis is a
complex process, involving many stages
and cell events. Second, epigenetic
events affect the gene, even if they do
not cause mutations, and certain
epigenetic effects can be inherited.
Some of these current assumptions
about cancer risk assessment have been
made more for the convenience of
computer modelers, number crunchers,
and statisticians as opposed to
biologists. These assumptions will have
to be revised to incorporate new
information on hormone-like activities
of chemicals, activators of incipient
cancer-causing genes known as
proto-oncogenes, immune suppressants,
and other complex actions that relate to
the overall process of carcinogenesis in
the organism.
If EPA is concerned to make risk
assessment more accessible to the
public, and to increase public
understanding and acceptance of this
methodology, the Agency should refrain
from accompanying every risk
assessment with the extensive litany
about the risk of everyday life and
uncertainty, which is currently invoked
in almost all Federal Register notices
and public statements. Second, the
Agency should devote more resources to
developing ways to identify and
evaluate the risks of noncarcinogenic
chemicals. Third, EPA should consider
the gaps between its assessments of risk
and its record of actions to reduce these
risks. Only when these processes appear
more in line can there be reasonable
expectation that the public will see
empirical value in the process, and only
by accepting this value will the public
be committed to participating in the risk
assessment and risk management
process, a
(Dr. Siibergeld is Chair, Toxics Program,
for the Environmental Defense
Fund.)
NOVEMBER 1987
35
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From the Outside:
An Industry View
by Robert C. Barnard
How does industry view scientific
risk assessment? Industry's attitude,
1 believe, stems from a basic position
that public health policy should be
based on the use of the best and latest
scientific data and understanding to
identity and control health risks. This
position is based on the principle that
scientific ('valuation of the character
and magnitude of the risk—scientific
risk assessment provides the best and
most informed input for regulatory
decisions and for communicating with
the public on risk.
We all understand that there are two
basic motives tor communication: one is
manipulative, the other is educational.
Scientific risk assessment is the basic:
educational tool that provides the risk
manager in government and in industry
with the basic information for sound
decisions on how to control risks. Risk
assessment is also the soundest
educational tool to inform the public:
about risk.
Practical Considerations
There are a number of practical
considerations that enter into industry's
support of risk assessment and its
support of efforts to improve the
process.
Kconomic Issues: The fall 1985 issue of
the National Academy of Sciences
maga/iue Issues reported a study
showing that the cost of managing risk
in the United Slates in 1978 amounted
to seven percent to 12 percent of the
gross national product. Half that
cost reflected damages or injury
compensation; the balance was the cost
of controlling risks. In real terms, many
companies are devoting 10 percent of
capital budgets and equivalent
proportions of research budgets and
technical personnel to deal with risk
management problems.
These figures are not cited because
they are too low or too high. Costs of
this magnitude—and they have
increased significantly since
1978—explain why industry supports
efforts to ensure that the best scientific
data are used so that controls are
appropriate—that is, reasonably related
to the true magnitude of the risk
involved.
Communication Issues: The soundness
of both the public perception and the
risk manager's decision on products and
controls depends on whether the risk
assessment gives the best and most
complete information science can
provide on the potential risk. Arthur
Hays Sulzberger, former publisher of the
New York Times, put the matter very
bluntly in a comment that applies to
both newspaper and scientific risk
assessment:
A man's judgment cannot be better
than the information upon which
he based it. Give him the truth and
he may still go wrong, but give him
no news or present him only with
distorted data, with ignorant,
sloppy or biased reporting, with
propaganda and deliberate
falsehoods, and you destroy his
whole reasoning process.
Some Background
These general concepts can be brought
down to earth if we look at the process
for assessing potential human cancer
risk.
The science of carcinogenesis is a
young science. Dr. Lewis Thomas.
Chancellor of the Sloan-Kettering
Cancer Center, called his magnificent
book The Youngesl Science.
Since the early 1970s, when the "war
on cancer" was announced, there has
been a spectacular growth in cancer
research in government, academia, and
industry. Although the data base has
grown exponentially, the list of human
carcinogens has remained virtually the
same over the past decade. What has
grown are the number of substances that
cause cancer at some dose in some
species of animals.
Scientific understanding of the
biological processes that lead to cancer
has grown markedly at the same time
the animal data base has grown.
Our understanding of how a
substance is handled in the
body—transported, changed, and
excreted—and the response of both
animals and man has advanced
remarkably. The simple yes/no
approach—an animal carcinogen is a
human carcinogen—has been replaced
by an increasingly sophisticated
analysis to determine the relevance of
the huge volume of experimental animal
data to human risk.
To take advantage of the new
scientific developments the analysis
becomes more complicated:
• Does the animal data provide insight
on the biological process that produced
the cancer: mechanism,
pharmacokinetics, or metabolism?
• In light of the animal data and
comparative human metabolic and
pharmacokinetic data, which animal
study is the best surrogate for man?
• Since even the best available
surrogate is not perfect, in what respects
does the surrogate fall short or differ
biologically from man?
• What combination of scientific:
judgment and risk assessment
Chemical analysis in a laboratory of the
Minnesota Mining and Manufacturing
Company. The lab performs assessment
services that help determine the
environmental impact of products and
processes.
3G
EPA JOURNAL
-------
Although the data base has
grown exponentially, the list
of human carcinogens has
remained virtually the same
over the past decade.
NOVEMBER 1987
37
-------
The bottom line is how we
can improve scientific risk
assessment so that we make
best use of the rapid advances
in science.
methodology best uses these scientific
insights to provide the "best" or "most
likely" estimate of potential human
risk?
What's the Problem?
The term "risk" implies uncertainty.
While science has made and is making
great strides in understanding the
biological processes that induce cancer,
we do not yet understand the
mechanism or mechanisms of action.
Each advance in science reduces the
area of uncertainty but at the same time
opens new areas for research.
How do we deal with the problems of
uncertainty and how do we take
advantage of scientific development?
The principal tools that EPA uses are
guidelines for scientific assessment: for
cancer risk, the Guidelines for
Carcinogenesis Risk Assessment. The
guidelines are a mixture of an
expression of scientific objective, along
with directions on methods to use to
assess risk. The guidelines emphasize
the importance of having a sound
scientific appreciation of the true nature
and magnitude of the risk. But to deal
with uncertainty, the guidelines specify
certain assumptions and procedures to
be used in the analysis. As EPA
recognizes, these are policy choices and
they are sometimes called "default
options." These default options are to be
used in the assessment unless facts
demonstrate otherwise. In practice, the
default options are used in virtually all
cases.
It has been said that the science is
dynamic, but the default options are
static. There is a tension between the
default options and the use of new
scientific developments.
Without being technical it helps to
illustrate. For example, EPA uses a
statistical procedure—known as a
"model"—for estimating the impact at
low doses of exposure to a substance.
Normally, the doses at which an
experimental animal is exposed is
hundreds or even thousands of times
higher than those which man commonly
experiences. There is no scientific
agreement on which extrapolation
model is appropriate. Since alternative
models use different mathematical
formulae for the estimate, the choice
can change the risk estimate by a factor
up to 10,000,000.
The extrapolation model the
guidelines select—the linearized
multistage model—was chosen
originally in 1980 and represented
operational consensus at that time.
However, the mode! uses only part of
the data actually or potentially
available: that part pertaining to tumors
as a function of doses. The EPA Science
Advisory Board has been recommending
that EPA use the pharmacokinetic data,
and EPA is exploring the use of an
alternative model to take advantage of
the newer data. Last summer, EPA
presented to the EPA Science Advisory
Board an analysis of methylene chloride
that included estimates from a more
advanced model incorporating
pharmacokinetic data, along with the
estimate from the standard model.
The choice of the data base to be used
in estimating risk is also important
because changes in the starting base can
have a large impact on the size of the
estimates. The default options also pick
the data base to be used: the results of
experiments using the most sensitive
species. The increasing scientific
understanding of the way animals and
man handle and respond to a substance
have revealed a class of cases where
there is no doubt about the fact that the
animal got tumors, but there is a
question about the relevance to man.
Unleaded gasoline is a good example. In
that case, science has clarified the
biological process by which male rats
get kidney cancers, and, since the
process is peculiar to male rats, that
understanding has raised a serious
question of the relevance to human risk.
EPA is aware of the problem.
What About the Future?
The question is how best to balance the
"inflexibility" of the default options
with the objective of improving the
scientific risk assessment by using the
latest scientific understanding and data.
Risk managers both at EPA and in
industry want a scientific evaluation of
the hazard and the human exposure that
is as accurate and complete as possible.
Public perception of risk depends on
confidence that the analysis has
presented the most complete
information science can provide.
Industry and government may not
always be in step regarding how long
we should cling to old concepts and
when we ought to move to use new
scientific developments in assessing
risk. Happily, however, there is general
agreement on the direction and the
objective. And both industry and
government agree that the objective
should be educational, not
manipulative. What is really being
discussed between industry and
government is the most effective
implementation.
The bottom line is how we can
improve scientific risk assessment so
that we make best use of the rapid
advances in science. When scientific
advances are used in the assessment,
research is stimulated. As we succeed in
improving the risk assessment process,
government, industry, and the public
will benefit. D
(Barnard is counsel to Cleary, Gottlieb,
Steen fr Hamilton, practicing in the
firm's Washington, D.C., office. He is
also attorney /or the American
Industrial Health Council and
represents a number of industrial
companies.]
38
EPA JOURNAL
-------
Environmental Journalism:
Inflaming or Informing?
A Forum
Some observers have accused
the media of sensationalizing
environmental stories. Others
believe journalists are doing
a good job of informing the
public about environmental
problems. Which point of
view best conforms to
reality? Are journalists
whipping up needless
hysteria with "Scare of the
Week" coverage? Or are they
accurately stating, perhaps
even understating, the
significance of environmental
stories as they arise?
EPA Journal asked three
journalism professors and
five environmental reporters
to address this issue.
The pesticide EDB on the nightly news on national television
before EPA acted to ban it. One of the major environmental
stories in recent years, it was a drama which stretched over
several months.
David B. Sachsman,
Choir, ncpnrtmrnf of
Journalism mid Muss
Miniiu. Hiit»ci\s
University
We collected the best
environmental risk stories
written in New Jersey in a
year, and we analyzed them,
using both content analysis
and experts. We found that
the articles were indeed more
alarming than reassuring, and
three of the four experts felt
that the articles painted a
more alarming picture of
New Jersey's environmental
issues than was justified by
the reality. What this says to
me, as a journalist and a
journalism professor, is that
scientists, government
officials, and industry
representatives do not truly
understand the role of the
press. It is, in fact, the
business of the press to cover
alarming news, and it is a
natural failing of the press to
ignore situations that are not
alarming. So by definition,
the press will always be more
alarming on any issue than it
will be reassuring.
(The research to which
Professor Sachsman is
referring is contained in a
book he co-authored with Dr.
Peter Sandman and Dr.
Michael Greenburg. The
book, entitled Environmental
Risk and the Press, mis
published in October 19H7 by
Transaction Press in Xriv
Brunswick, A'/.j
Robert E. Taylor, \\ull
Stnii'l Journal
The media both inform anil
inflame. The quality of
environmental reporting mi
environmental and health
risks is as varied as reporting
on arms control or any other
complex topic. Officials.
companies, and
environmentalists often make
misleading statements. Many
reporters oversimplify- My
NOVEMBER 1987
39
-------
Cleaning up a beach after the
Santa Barbara oil spill in
1969. This widely reported
incident contributed to the
environmental awakening
which was taking place in the
U.S.
flesh still crawls when I hear
the question repeated, "Just
tell us if it's safe." The
question should be, "How
safe, or compared to what?"
But the general quality of
coverage is improving, and
public: attitudes are changing.
The lack of response to the
recent discovery of dioxin
traces in paper may show the
public can accept low risks.
On the other hand, it may
show people are just tired of
hearing about the cancer
"threat of the week."
Philip Shabecoff,
'/'lie \cu Vork Tinn.'.s
(Coverage of environmental
issues by the national media.
particularly the national print.
media, has become
Increasingly sophisticated
and knowledgeable over the
past decade. I think we look
hard at the science and
economics of environmental
policy issues in ways we did
not when the issues first
became important news. As a
reporter. I only respond to
what emerges from the
Environmental Protection
Agency and the other sources
of news that I cover, and I try
to reflect accurately what is
communicated to me by the
Agency. The other side of the
coin is that policymakers and
their spokesmen in this field
have become increasingly
sophisticated in
communicating their message
to the press.
Sharon M. Friedman,
Choir, D<:p
-------
t *.V,' 1A
• :•> . -< »
Guy Darst, Associated
Press
Environmental journalism is
more and more effectively
informing the public. As we
as a society accumulate
experience, we are better able
to get a real handle on what's
important for the public to
know and what is simply
flashy but not that important.
I think this is true of all sorts
of topics, not just the
environment but also public;
health, individual health,
foreign policy, etc. New
concerns come up and when
a whole new cluster of issues
comes to public attention,
this always stimulates a
scramble by people in the
press to bring the new to
public attention. This process
by which the press and other
institutions—Congress,
advocacy groups, corporations.
universities—get a handle on
what's important and what
isn't important has been
going on in the
environmental area for
several years and will
continue to go on.
Robert Logan,
IJimclor. Science
fournalism Confer,
! 'nimrsily of Missouri
School of
Science and environmental
coverage are more effective in
larger metropolitan
newspapers that have better
trained reporters and more
internal resources than small
or medium-size newspapers.
On television, coverage varies
widely. The very nature of
television, with it.s emphasis
on visual impact, means that
news reporting often appears
to be unnecessarily
inflammatory to many
scientists. Television is
sensational per se. 1 think
that fact is often overlooked
by television's critics.
Also, all journalists, no
matter how skilled they are,
have problems when there's
a fast-breaking news story
where the reporters have
little experience with the
events. When the story is
new or unique and needs to
be reported in several
minutes, well-intentioned
mistakes can be made by
anybody. Many
environmental stories have fit
this category in the past
decade. Some environmental
stories happened quickly and
needed to be reported
immediately to calm public
fears, and even well-trained
reporters had little frame ot
reference regarding the
particular chemical or other
environmental issue they
were reporting about. The
real test of a good news
organization is how well they
follow up a story during the
days after a major
environmental event or crisis,
when they have a little more
time to piece the story
together and the reporters
develop some knowledge and
expertise about the subject. D
NOVEMBER 1987
41
-------
Protecting
Cape Cod's
Ground
Water
by Greg Supernovich
'utsetts
Toll someone your well water on Cape
Cod is replenished by an
underground river flowing from the
mountains of New Hampshire, and your
listener is apt to wonder if you've spent
too much time in the sun. But such
disbelief wasn't always the case. Many
believed the underground river story
even a decade ago. The fact that most
Cape Coddcrs now consider the story
part of their folklore shows that new
scientific research into ground water has
dramatically changed their
understanding of water supplies.
In retrospect, it seems illogical that
many Cape Codders accepted the
underground river story. (Jape Cod is a
relatively narrow sand and gravel
peninsula in southern Massachusetts
that curls like a flexed arm as it
stretches more than 50 miles into the
Atlantic Ocean. The New Hampshire
mountains lie hundreds of miles to the
north. Several major rivers and canals,
not to mention the ocean, separate the
Cape from the mountains. How could an
underground river pass beneath these
geographic features'!1 Yet the story
persisted.
Perhaps its origin can he traced to
early native Americans who lived on
the Cape after the sandy spit of land
was formed by receding ice masses
12,000 years ago. Perhaps the story
evolved because (Jape Cod's drinking
water—rain water that has filtered
through natural layers of sand and
gravel into underground
reservoirs—tastes like cool, clear
mountain water. Perhaps the legend
survived because there weren't enough
facts to prove otherwise.
Officials say that dispelling the
underground river myth on Cape Cod
and breaking down resistance to new-
ideas have probably been the most
difficult tasks they have encountered
during their fight to protect Cape Cod's
billions of gallons of ground water.
"It comes down to this. If you were
having a homo built, you drilled a well
in your front yard and dug a pit in the
back and put in a septic tank. You'd be
concerned. You'd want to believe in an
underground river from Lake
Winnepesaukee (in New Hampshire).
People don't want to believe they are
putting waste into their well, and yet
that's the case," says Michael Frimpter,
chief of the Massachusetts office of the
U.S. Geological Survey.
One of tbe main problems, according
to Frimpter, is that ground water is
invisible. The challenge is to help
people who draw their water from wells
realize that they live on top of their
aquifer—on top of their reservoir—and
that whatever they discharge into the
ground will likely find its way into their
drinking water.
Cape Cod's aquifer is extremely
fragile. Its porous sand and gravel
subsurface not only allows rain water to
easily recharge ground water, it also
facilitates the passage of man-made
pollutants into the aquifer. One toxic
spill could contaminate the water of a
hundred thousand people. And it would
be exorbitantly expensive, if not
impossible, to pipe in water from other
parts of Massachusetts.
Despite this natural limitation,
however, the (Jape is one of the fastest
growing counties in the United States.
New condos, houses, and businesses are
popping up everywhere. The (Jape's
winter population of 170,000 swells to u
half million in the summer as
vacationers flock to the beaches.
cottages, and resorts.
Yet, while the Cape is booming, the
water supply remains constant. (Jape
(Jod has only one principal source of
water. EPA has designated it as a Sole
Source Aquifer, a special federal status
for aquifers that supply at least 50
percent of the drinking water for an area
that has no reasonably available sources
if those aquifers become contaminated.
Tbe Cape's ground-water programs are
among the most advanced in the nation.
They have to be to protect the Sole
Source Aquifer. Early studies of the
Cape's ground water indicated that a
single interconnected aquifer supplied
all of (Jape (Jod's 15 towns.
"The people on the (Jape drink from
the same cup. If anyone is allowed to
contaminate that cup, the contamination
will remain for generations. Hence, it's
in everyone's interest to keep that cup
as clean as possible," says Michael
Deland, EPA's regional administrator in
Region 1. And even though more recent
geological surveys have revealed not
one, but six aquifers on the peninsula.
Deland still finds the cup analogy
useful. It teaches people that water
issues cross town lines just as aquifers
cross town borders.
EPA officials say they are beginning
to see improvements in ground-water
protection on the Cape, but they warn
that much more needs to be done.
Armando Carbonell, the executive
director of the Cape Cod Planning and
Economic Development Commission,
says he has seen attitudes about water
supply on the (Jape change rapidly in
recent years. "Every (Jape (Jod Chamber
of Commerce puts ground-water
protection at the top of its list." he says.
"The business community recognizes its
survival is dependent on the protection
of its resource."
New ground-water programs have
spurred the changes: Officials have
spent millions of dollars studying the
location and flow of the (Jape's ground
water. Several (Jape towns have each
bought hundreds of acres of land
around their wells to keep the land
undeveloped in order to protect the
quality of the water passing through the
wells' "zone of contribution." Some
towns have tightened up x.oning laws to
prevent dense residential development
or industrial growth in well-field areas.
Some towns have begun to regulate and
monitor underground tanks and
landfills and are using less salt on their
roads to melt snow. Their police and
fire departments have learned to absorb
spills from car accidents instead of
washing the contaminants into a ditch.
A few businesses have learned to store
hazardous waste properly. And nearly
42
EPA JOURNAL
-------
Teamwork
Local, state, and federal agencies
may have excellent programs and
regulations to protect ground
water, but contaminants frequently
pollute the drinking water anyway
because the agencies don't
coordinate their efforts.
To keep this from happening on
Cape Cod, government officials are
building "institutional teamwork"
into the two-year Cape Cod
Aquifer Management Project
(CCAMP) in Massachusetts. The 35
people working on the project
represent six branches of
government, including EPA's
Region 1 Office (Boston), the
Massachusetts Department of
Environmental Quality
Engineering (DEQE), the Cape Cod
Planning and Economic
Development Commission, the
U.S. Geological Survey, and the
towns of Barnstable and Eastham.
Their goal is to better understand
how to manage ground-water
protection at all levels of
government through an intensive
study of land-use activities around
water supply wells.
Barnstable and Eastham were
chosen to participate in CCAMP
because together they span Cape
Cod's ground-water problems.
Barnstable, a town of seven
villages, has a major business and
population center, a wastewater
treatment facility, and extensive
public water-supply systems.
Eastham is a rural community with
only private wells, no full-time
public health officer, and a
primarily seasonal economy.
Some say that the CCAMP
project is a national prototype.
"We want to have an all-out attack.
We don't want to just see landfills
or underground tanks as a threat,
but to ask, 'What is in that area
and what will the problems be?'"
says David Pierre, of EPA's Region 1.
Tara Gallagher, CCAMP project
coordinator at DEQE, said that
some effects of the program might
be to prevent problems such as a
proposal by a public works
department to build a solid waste
transfer station near a well, or a
plan by a town to locate an
industrial park near another town's
well.
Robert Mendoza, director of
EPA's office of ground-water
protection in Region 1. said that
CCAMP's wellhead protection
project will probably lead to a
redefinition of the "zone of
contribution," which is the land
area around a well through which
rainwater passes into a well's
aquifer. Traditionally, a 400-foot
radius has been accepted as the
zone of protection around public
wells in Massachusetts. However.
Mendoza says that DEQE is finding
that this protection area in some
cases needs to be a thousand feet
or greater.
In addition, CCAMP's staff is
expected to produce water-table
maps and land-use maps,
recommend where to situate
facilities such as landfills and
sewage treatment plants, inventory
underground storage tanks, and
suggest protections for private
wells. The staff will also design a
computer system that will display
potential ground-water threats in
such a way that decision-makers
will be better able to see the
consequences of their decisions.
CCAMP is cost-efficient. Very
little money is being spent on the
project. Only one new person (the
coordinator) was hired. All the
other CCAMP staff had already
been working on related issues at
their agencies. At EPA, a
hydrologist, an environmental
protection specialist, a computer
specialist, and a manager are
spending part of their work-time
on the project.
every town now has a water-quality
advisory committee to plan
ground-water management programs.
"We still have near disasters. That's
scary. What it suggests is: us smart as
we've become, we have to become
smarter," Carbonel! says.
Thomas Mullen, the former water
superintendent for 15 years at one of the
four water districts in the town of
Barnstable on Cape Cod, was one of the
first local officials to sound the alarm
about ground water. Initially, he says,
he met widespread opposition; people
didn't want "outside" consultants
telling them how to manage their water
supply. Yet the town was headed on a
collision course. Its water supply and
land use were in conflict with each
other. Although the Cape's county
government began to get actively
involved in ground-water programs
about 10 years ago. Mullen says that
many of Barnstable's branches of town
government only started their water
protection efforts three years ago.
According to Mullen, one of the
recent ground-water battles in
Barnstable centered on Cape Cod Potato
Chips, a business located 1.000 feet
from one of the town's wells. The
A deputy chief in one of the fire
departments in Barnstable is
responsible for making sure that
underground storage tanks are safe and
do not pose a threat to a fragile
aquifer.
company wanted to discharge daily into
the ground a large amount of treated
wastewater from its potato-peeling
operation, However, the ground was
part of the area that contributed wator to
the town's well, and local officials
feared that the discharge would .uld
excess nitrates and salt to (he xveli. As .1
result, they spent $5.5 million to buy
and protect (i5 acres of open land
around the well, while also convincing
Cape Cod Potato Chips to truck its
waste to the town's sewage treatment
plant.
Many in the village of Barnslabh: do
business differently now that there is a
new awareness about ground water. The
owner of a small auto tuneup station
should no longer carelessly store waste
oil and waste antifreeze. To prevent
NOVEMBER 1987
43
-------
At the docks on Cape Cod. While
recreation has boomed on the Cape,
(jround-water supplies remain the same.
spills or leaks, tin; wastes should be
poured into drums that are placed
insiclfi other plastic drums and then
strapped to a wall.
Lester Mason, a deputy fire: chief who
heads an underground tank program at
one of the fire departments in
Barnstable, also handles his job
differently than he did several years
ago. He is now responsible for hundreds
of underground tanks holding petroleum
products or chemicals, all of which
must be registered, tested, and replaced
when necessary. Mason is fully aware of
the danger that leaking underground
tanks pose to ground water. A vacant lot
is no longer just an empty lot to him. It
may contain buried, corroding tanks full
of oil or sludge that could leak and
pollute (he water supply.
Ground-water vigilance on Cape Cod
did not begin easily. It took several
crises before people understood its
importance. In 1977, 3,000 gallons of
gasoline from a leaking underground
tank at a gas station in Truru knocked
out one of the main wells for
Provincetown. Cleanup of the well so
far has cost approximately $3 million.
In recent years, Falmouth and Mashpee
have also lost wells due to
contamination from a sewage treatment
plant at the Massachusetts Military
Reservation.
Meanwhile, the Center for Health
Promotion and Environmental Disease
Prevention of the Massachusetts
Department of Public Health is trying to
determine the cause of elevated levels of
leukemia and lung cancer in Falmouth,
Mashpee, and three other Upper Cape
towns. Massachusetts public: health
spokesman John Stobierski says that if
the center finds clusters of people with
cancer, ground-water contamination or
air pollution may be the cause.
Other efforts are also underway. The
U.S. Geological Survey is studying how
bacteria and dissolved contaminants
move and disperse in ground water,
using ground-penetrating radar to map
the elevation of the water table. And the
Cape's county health department is
purchasing an automated gas
chromatograph to test water supplies for
volatile organic compounds.
The new knowledge about aquifers on
Cape Cod clearly indicates that ground
water nationwide is endangered not
only by steel mills or chemical plants,
but by sources perceived as less
threatening, such as gasoline stations,
homes, the town landfill, or the local
laundromat. "The prevention of
ground-water contamination is a much
more intelligent approach than cleanup.
Cleanup is expensive," explains David
Fierra, director of the water division in
EPA's Region 1. "Prevention is largely a
land use activity. It involves a conflict
of economic development and
environmental conservation. Hut
without potable water, economic;
development is not possible, and people
will learn that sooner or later."
Region 1 Administrator Michael
Deland adds that aquifer studies on
Cape Cod will prove invaluable to many
other parts of New England, where 90
percent of the rural population is solely
dependent on ground water for drinking
water, and 77 percent of the municipal
water systems are dependent on ground
water. "We need to zealously guard
ground water not only for ourselves," he
says, "but for our children and those to
come." n
(Supernovicri is it writer/editor in the
Office of Public Af/uir.s in KPA's
Region 1.}
44
EPA JOURNAL
-------
The
Lower Hudson;
Environmental
Resource
in Megacity
Around the base of an ancient
island-mountain created over 400
million years ago, a wide natural harbor
forms where the fresh waters of the
Hudson blent! with the cold salt of the
Atlantic. Many species of birds and fish
still come to New York harbor to feed
and spawn, and on the bottom of New
York harbor lie remnants of oyster beds
once counted among the richest in tin;
world.
Centuries ago, Dutch sailors who
dropped anchor at the mouth of the;
river the Indians called Muhheakunnuk
reveled in a land whose woods and
marshes teemed with mountain lions,
bears, beaver, elk, swans, and geese. In
spring, Manhattan Island was cut in half
by flooding streams that flowed where
traffic-choked Canal Street today forms
a barrier between Little Italy and
Chinatown.
There was a time when New York
City's 578 miles of waterfront were the
focal point of the region's economy and
culture. Pier after pier of sloops,
clippers, steamboats, and fishing vessels
lined the harbor, alive with sailors and
merchants and news of commerce from
around the world. And there was talk of
the clay's fishing. Then, as now. the fish
outnumbered the people. Besides the
legendary striped bass that migrate
between fresh and salt water, the waters
were plentiful with white perch, shad,
sea sturgeon, bluefish, tomcod, killifish,
eels, menhaden, alewifu, winter
flounder, herring, clams, mussels, and
blueshell crabs, just out to sea, there
were whales.
Much has changed since then, but
despite more than two centuries of
industrial pollution, overfishing,
dredging, mining of the river bottom.
toxic contamination, daily pumping of
raw sewage, thermal pollution from
power plants, and systematic
by Tom O'Keeffe
Marshlands and Manhattan: the natural
environment in the big city.
destruction of marshland and river
habitat, these species still inhabit harbor
waters, some in surprising numbers.
And, according to EPA and U.S. Fish
and Wildlife Service experts.
anti-pollution efforts over the last 15
years have resulted in dramatic
improvements in water quality, with
markedly positive effects on marine life.
Continuing projects promise to restore
much of what years of neglect took
away.
The wildlife that has survived has
been able to adapt to human progress.
As the wetlands they depended on for
nutrients and spawning grounds were
filled in, fish came to rely instead on
the areas in and around the piers, where
pilings slowed the water and fish could
rest, spawn, and feed. This made the
"interpier" area between and around
docks excellent grounds for waterfowl
and the migratory birds for whom the
Hudson River valley is a major l']yw
-------
communities are scrambling to create a
riverfront renaissance of spectacular
commercial and residential properties,
of fishports, marinas, and recreational
areas. For New Yorkers, a condominium
with a waterfront view means city
lights, harbor lights, moonlight, and
candlelight. A one-bedroom
condominium with a fireplace, a
balcony, just ten minutes from work, a
marina...such places are selling instantly
at regal prices.
In the planning stages or under
construction are some 59 major projects
on the East and Hudson rivers. In
Manhattan, one success story is the
South Street Seaport, whose shops,
markets, and visiting sailing ships recall
the romance of New York's maritime
tradition, bring in tidy income for its
merchants and the city's coffers, and
entertain millions who visit each year.
All this development has sparked
debate over the competing uses of the
Hudson. The issues at stake are
economic, environmental, and aesthetic,
and involve the interests of industry,
sportsmen, ecologists, developers,
community leaders, planning officials,
and fishermen.
Planners say the current development
is haphazard. Because the harbor is
shared by New York City and eight
municipalities on the New jersey side
and comes under the jurisdiction of
numerous regional, state, and federal
agencies, decisions about how the
region should develop are being made
on an isolated, case-by-case basis with
little attention being given to their
cumulative effects. The result may be a
patchwork of unorchestrated
commercial and residential projects that
place unplanned-for strains on regional
transportation, utilities, public
amenities, and services.
Environmentalists fear that the
proposed projects could destroy fragile
habitat that supports fish and birds. Key
to many plans is the construction of
high-rise buildings on platforms over
the river on reinforced piers in an
attempt to comply with the
environmental restrictions on the use of
fill. While developers argue that the
platforms will not damage the interpier
habitat, the possibilities, yet unstudied,
disturb many.
Platforms, they suggest, would block
light needed for photosynthesis, and
water slowing down among the pillars
may deposit silt that would build up
and create a landfill over time. Some
fear that multi-million dollar platforms
that begin to fail are likely to be
reinforced not with new piling but with
landfill. Proposed marinas may threaten
wildlife with added petrochemical
pollution and turbulence.
At the root of these concerns is a lack
of knowledge about how much and
Out on the docks, there is the
wail of gulls and the smell of
money.
what kind of habitat exists in the area,
and how much is needed to sustain
wildlife. Knowing which areas are most
important should be the first step to
sound planning for development, but
these critical environmental questions
have so far gone unanswered. This lack
of knowledge notwithstanding,
waterfront land-use choices are being
made, one by one, that will have a
profound and permanent effect on the
quality of life for New Yorkers now and
in the future.
These choices are being made in a
tangle of overlapping local, state,
regional, and federal jurisdictions whose
decisions often seem to check and
countercheck each other. Most Clean
Water Act Section 404 permit decisions,
for example, require developers to deal
with as many as 12 agencies and
government bodies, each with its own
concerns about what costs and benefits
the project will bring. Federal agencies
involved may include EPA, the U.S.
Army Corps of Engineers, the U.S. Fish
and Wildlife Service, the Federal
Highway Administration, and the Coast
Guard.
Yet despite the number of
regulatory agencies and involvement
from communities, the progress of
development projects through the
regulatory process is often complicated
by failure to analyze environmental
impacts early on. The ensuing
regulatory battles work to the
disadvantage of both the developments
being proposed and the environment
itself.
One memorable example of the
paralysis of decision-making that may
result is the 14-year-long battle over the
West Side Development Project, known
as Westway, whose proposed highway
and landfilling threatened to destroy
valuable interpier habitat used by the
striped bass. The project pitted planning
officials and developers against the
environmentalists and the fishing
industry. After years of exhaustive
debate and expensive lawsuits, the
project was scrapped.
This policy paralysis, a syndrome
EPA's Region 2 Administrator,
Christopher Daggett, calls
"environmental gridlock," often results
in decisions made through indecision or
unsatisfactory compromise. Until those
who hold an interest in the New York
waterfront join together to face tough
questions head-on, Daggett believes,
critical environmental issues will go
unresolved.
Predicting that other projects may face
the same fate as Westway, Daggett has
proposed the formation of a
multi-agency task force that would
identify critical habitat in advance of
development proposals. The group, to
be comprised of representatives of
community groups and developers as
well as officials from local, state, and
federal agencies, could come to
agreement ahead of time as to which
areas along the Hudson, East River, and
the Harbor front should be targeted for
development and which preserved as
valuable habitat for wildlife.
Such joint undertakings have already
shown promise elsewhere in the region;
Daggett has suggested that a major
cooperative initiative now underway to
protect New jersey's Hackensack
Meadowlands serve as a model for the
Hudson and East Rivers. The
Hackensack initiative calls for a
comprehensive evaluation of the area's
numerous wetland tracts and
interagency and public review of the
findings. The result, it is hoped, will be
a system identifying those tracts that are
of critical environmental importance
and those that may be safely developed.
Daggett hopes that the task force
initiative will prompt local officials to
begin viewing their development
activities in a more regional perspective.
With positive response so far from
public officials and a quiet wait-and-see
attitude among developers, he hopes
that the gridlock can be tamed.
But out on the docks, there is the wail
of gulls and the smell of money. There
the future is developing brick by brick.
And so far, no one can tell what it will
look like when it arrives, a
(O'Keeffe. is a pubJic affairs specialist
with EPA's 0//i'ce of External Programs
in the Region 2 Office.)
46
EPA JOURNAL
-------
Update
A review of recent EPA activities.
AGENCYWIDE
Environmental Youth
Awards
In a ceremony held at EPA
headquarters on November
16, EPA Administrator Lee
M. Thomas and Nancy J.
Risque, Assistant to President
Reagan and Cabinet
Secretary, presented the
President's 1987
Environmental Youth Awards
to ten winners: the Fourth
Grade Class at Woodland
Elementary School in
Woodland, ME; the
Environmental Studies
Laboratory at John D. Wells
junior High School Number
50 in Brooklyn, NY; David
Andrew Shemenski, a
student at Linsly High School
in Wheeling, WV; Amy
Bustle, a student at Lexington
High School in Lexington,
SC; the Aquatic Biology Class
at East High School's
Summer Session in Madison,
WI; the Leona River Ecology
Project at Uvalde Middle
School in Uvalde, TX; the
Outdoor Classroom at
Guthrie Center Elementary
School in Guthrie Center, IA;
the Eighth Grade Class at
McGinnis Middle School in
Buena Vista, CO; Bill Buck, a
student at Righetti High
School in Santa Maria, CA;
and the Salmon Project at
Phantom Lake Elementary
School in Bellevue, WA.
AIR
Vehicle Tampering Survey
EPA issued results of its 1986
Motor Vehicle Tampering
Survey. The survey
concludes that one out of
every five passenger cars or
light-duty trucks shows
evidence of tampering with
at least one component of the
emission-control system. EPA
categorized 54 percent of the
surveyed vehicles as "okay"
in 1986, as opposed to 52
percent in 1985.
Auto Recall
EPA recalled 125,600
Chrysler, Dodge, and
Plymouth passenger cars to
correct an excessive
hydrocarbon and nitrogen
oxides emission problem.
The affected models were
certain 1982 Chrysler
LeBarons and Town and
Country Wagons; Dodge 400s,
Aries, Omnis, Aries Wagons
and 024s; and Plymouth
Horizons, Reliants, TC3s, and
Reliant Wagons. All are
equipped with 2.2-liter,
four-cylinder engines.
HAZARDOUS WASTE
Love Canal Decision
EPA announced its final
decision for the Superfund
cleanup of Love Canal creeks
and sewers in Niagara Falls,
NY. The selected remedy will
use on-site thermal
destruction to clean up the
dioxin-contaminated creek
and sewer sediments. The
residuals from thermal
treatment will be disposed of
on site. The estimated cost of
the entire remedy is between
$26 and $31 million.
SITE Program Selections
EPA selected 10 developers
to demonstrate technologies
under the Superfund
Innovative Technology
Evaluation (SITE) program.
The SITE program helps EPA
to demonstrate, evaluate, and
promote the use of new
technologies that
significantly decrease the
toxicity, mobility, or volume
of Superfund hazardous
substances. The selected
developer pays for the
demonstration while EPA
finances the evaluation.
Selected this year were: for
solidification/stabilization
processes: Solidtech, Inc., of
Houston, TX; Chemfix
Technologies, Inc., of
Metrairie, LA; Waste Chem
Corp. of Paramus, NJ; and
Battelle Pacific Northwest
Laboratory of Richland, WA;
for biological technologies:
Air Products and Chemicals,
Inc., of Allentown, PA;
Zimpro Environmental
Control Systems of
Rothschild, WI; and MoTec,
Inc., of Mt. Juliet, TN; for a
thermal technology, Retech,
Inc., of Ukiah, CA; for an
extraction process, C.F.
Systems Corp. of Cambridge,
MA; and for an ion-exchange
technology, Sanitech, Inc., of
Twinsburgh, OH.
PESTICIDES
Tributyltin Restrictions
EPA is proposing restricted
use of antifoulant paint
products containing
Tributyltin (TBT) pesticides
after determining that these
products may present
unreasonable risks to
non-target aquatic organisms
such as mussels, clams,
oysters, and fish. The
proposed EPA actions on
TBT antifouling paints
include prohibiting the use of
TBT antifouling paint on
non-aluminum-hulled vessels
less than 65 feet long;
classifying these products for
restricted use and limiting
sales to certified commercial
applicators; and new use
instructions for TBT labels.
ODM Review
EPA has begun a special
review of pesticide products
containing
oxydemeton-methyl (ODM)
and restricted their use to
certified applicators. The
Agency has concluded that
exposure to this chemical
may result in adverse
reproductive effects to
persons mixing, loading, and
applying it, and to
field workers who may enter
treated fields.
WATER
New Disinfection and
Filtration Requirements
Under the authority of the
Safe Drinking Water Act.
EPA proposed new standards
directing local water-supply
operators to filter their water
under certain conditions and
to disinfect it to protect
against Giardia, coliform
bacteria, viruses,
heterotrophic bacteria,
turbidity, and LegionelJa.
These new standards
consist of two separate
proposals that expand the
microbiological controls EPA
has placed on coliform
bacteria and turbidity since
1977: disinfection and (in
some cases) filtration
requirements, which apply
only to public water systems
that draw water from
surface-water sources, and
proposed coliform-bacteria
standards that apply to all
public water systems,
regardless of whether they
draw water from surface or
ground-water sources.
New Water Pollution
Standards
EPA issued a comprehensive
regulation to control water
pollution from the organic
chemical, plastic, and
synthetic fiber industries.
These standards, called
effluent limitation guidelines,
require these industries to
use the best practicable
control technology for some
types, of pollution and best
available control technology
economically achievable for
other types. The rules also
include special standards for
new sources and
"pretreatment" standards for
existing and new sources that
discharge into publicly
owned sewage-treatment
systems rather than
directly into rivers, streams,
and other waterways. D
NOVEMBER 1987
47
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Appointments
Linda |. Fisher has been
nominated by President
Reagan to lie KPA Ass is)nut
Administrator for the Office
of Policy, Planning and
Evaluation (OPPK]. In that
position, she will oversee the
Agency's development of
policy and manage its
regulatory process. Fisher,
who is Executive Assistant to
EPA Administrator Lee M.
Thomas, served as the
Agency's chief expert on the
reauthorization of Superfund
in 1980. She also has served
on the staff of the 1 louse
Appropriations Committee
and as a legislative; assistant
to two congressmen.
A native of Columbus, OH.
Fisher is a graduate of (lie
Ohio State University College
of Law and Miami University
in Oxford, OH. When
confirmed by the Senate, she
will succeed Milton Russell.
who resigned in March, as
Assistant Administrator for
OPPK.
Charles L. Grizzle has been
nominated by President
Reagan to bo EPA's Assistant
Administrator for
Administration and
Resources Management. He
will be responsible for
providing executive support
for Agency programs and the
management of financial and
budget policy and operations;
Senior Executive Service and
executive staff and the EPA
Institute: Agency-wide ADP
processing and procurement,
data management, and
computer network design;
and personnel, grants and
contracts, facilities manage-
ment, and management and
organization. Grizzle served
as Deputy Assistant Secretary
for Administration at the
Agriculture Department since
19K3. and was an assistant to
the Secretary and staff
assistant to the Director of
the Office of Operations and
Finance after he joined
USDA in 1982. Before
coming to Washington, he
served as Executive Director
of the Republican Party of
Kentucky and was a banking
officer in Lousiville.
Griz/le was born in Agrillite
(Greenup County), Kentucky,
and earned his bachelor's
degree from the University of
Kentucky in Lexington. After
Senate confirmation, he will
succeed Howard Messner,
who resigned in May.
Henry B. Frazier, III, has
joined EPA as an
Administrative Law Judge.
Prior to his appointment at
EPA, Judge Frazier served as
a member of the Federal
Labor Relations Authority for
eight years, including a
period as its Acting
Chairman from 1984 to 1985.
Before joining the Federal
Labor Relations Authority,
Frazier was with the Federal
Labor Relations Council for
nine years. During the last
six of those nine years, he
was the Council's Executive
Director. Prior to joining the
Council, Fra/ier—an Air
Force veteran—held several
civilian positions in the
Department of the Army,
including Chief of Civilian
Personnel Policy and Civil
Rights in the Office of the
Assistant Secretary for
Manpower.
* •- I
A member of the Virginia
and District of Columbia
Bars, Judge Frazier holds a
J.D. with honors from George
Washington University Law
School, and an LL.M. in
Labor Law and a Master of
Laws in Taxation from
Georgetown University
Graduate Law Center. He also
holds a B.A. with Honors in
Political Science from the
University of Virginia, whose
alumni association he headed
in 1985-6. He is a member of
Phi Beta Kappa, the Order of
the Coif, Omicron Delta
Kappa, the Raven Society,
and Phi Eta Sigma, o
Further Readings on Risk
Covello, Vincent 'I'.. Uetlof vtm
Winterfeldt, and Paul Sluvic,
"Risk Communication: A
Review of tin: Literature," Hisk
Absfracfs. Vol. :t. No. 4 (October
19H(i). 171-182.
Davies. Clarence (.. Vincent T.
Covello. and Frederick W.
Allen, Risk Communication.
I'mt eedings of ifte \uliomif
Conference on Hisk
Communication, January 2<)-;n.
liiflfi, Conservation Foundation.
Washington, D.C.. isiH?.
Discover. June 198f> (various
articles).
Douglas. Mary, and Aaron B.
Wildovsky. Risk and
Culture: An Kssm' on l/ic
Selection of Technical and
Km ironmental Dangers.
Berkeley: University of
California Press, 1982.
Fischhoff. Baruch, Paul Slovic, and
Sarah Lichtenstein, "Lay Foibles
and Expert Fables in Judgments
about Ki.sk." The American
Sfotisliciun, Vol. 36, No, 3
(August 1!)H2], 24(>-25f>.
Fisher, Ann. "The Scientific liases
for Relating Health Effects to
Exposure Levels,"
Kni'ironmenldl Jnipucl
Assessment Review. Vol. 3, No.
1. 1982.
National Academy of Sciences,
Risk Assessment in the Federal
Government: Managing the
Process. National Academy
Press. Washington. D.C.. 1983.
"Risk, Playing the Odds: A
Worrier's Guide to the 20th
Century," Science; '85. October
1985, (several other articles on
risk are in this issue.)
Sandman. Peter M.. "Explaining
Environmental Risk: Some
Notes on Environmental Risk
Communication," pamphlet
published by U.S. EPA, Office
of Toxic Substances, November
1986.
Science, April 17, 1987 (several
articles on risk).
U.S. EPA, Risk Assessment and
Management; Framework /or
Decision Making, EPA
600/9/85-002, December HW4.
U.S. EPA, "Risk Assessment.
Management. Communication:
A Guide to Selected Sources,"
EPA IMSD/87-002, March 1987.
periodic updates.
EPA documents
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An EPA press conference. The Agency is
involved in some of the most
hotly-debated issues of the day.
Back Cover: A dusting of snow on
Union Carbide's chemical works in
Institute, W.Va. The chemical industry
boomed with America after World War
II, producing a flood of new, widely
used products. More sophisticated
science has revealed that many
chemicals have potentially serious
health effects, such as cancer. Industry,
the government, environmental groups,
the media, and the public are focusing
now on how the risks from these
chemicals can be assessed and dealt
with while preserving the benefits and
the economic viability of the society.
Union Carbide in West Virginia recently
held an open house attracting more
than 12,000 visitors. Photo by Drew
Harmon, Folio, Inc.
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