EPA/SAB/79/001 Review of "A Method of Assessing the Health Risks Associated With Alternative Air Quality Standards for Ozone" (Draft dated July 1978J A Report of the Subcommittee on Health Risk Assessment September 1979 Science Advisory Board U.S. Environmental Protection Agency Washington, D.C, 20460 ------- EPA NOTICE This report has been written as part of the activities of the Science Advisory Board, a public advisory group providing extramural scientific information to the Administrator and other officials of the Environmental Protection Agency. .The Board is structured to provide a balanced expert assessment of the scientific matters related to problems facing the Agency, This report has not been reviewed for approval by the Agency, hence its contents do not necessarily represent the views and policies of the Environmental Protection Agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use. ------- SCIENCE ADVISORY BOARD SUBCOMMITTEE ON HEALTH RISK ASSESSMENT Chairpersoni Dr. Anita S. Curran, Commissioner, Department of Health, Westchester County, County Office Building 2, 150 Grand Street, White Plains, New York 10601 Members; Dr. Bernard Altshuler, Institute of Environmental Medicine, New York University Medical Center, 550 First Avenue, New York, New York 10016 Dr. Judy A. Bean, College of Medicine, Department of Preventive Medicine and Environmental Health, University of Iowa, Iowa City, Iowa 52242 Dr. Jennifer L. Kelsey, Associate Professor of Epidemiology, Yale University School of Medicine, Department of Epidemiology and Public Health, 60 College Street, New Haven, Connecticut 06510 Dr, John Logsdon, Director of Graduate Program in Science, Technology, and Public Policy/ George Washington University, Washington, D.C. 20052 Dr. Granger Morgan, Department of Engineering and Public Policy, Carnegie-Mellon University, 5000 Forbes Avenuet Pittsburgh, Pennsylvania 15213 Dr. D, Warner North, Decision Focus Inc., 1801 Page Mill Road, Palo Alto, California 94304 Dr. Geoffrey Watson, Chairman, Department of Statistics, Fine Mail, Princeton University, Princeton, New Jersey 08540 SAB Staff; Mr. Lloyd Taylor, 'Staff Officer (Until July 6, 1979), Science Advisory Board, A-101, U.S. Environmental Protection Agency, Washington, D.C. 20460 Ms, Sarah Mills, Staff Assistant, Science Advisory Board, A-101, U.S* Environmental Protection Agency, Washington, D.C. 20460 (Until July 26, 1979) Mr. Ernst Linde, Staff Officer (After July 6, 1979), Science Advisory Board, A-101, U.S. Environmental Protection Agency, Washington, D.C. 20460 Phone: (202) 472-9444 ------- INTRODUCTION The Subcommittee on Health Risk Assessment of the Science Advisory Board was established to advise the Agency on methodologies for assessing the health risks of various environmental pollutants. The Subcommittee was requested to review the methodology proposed by EPA's Office of Air Quality Planning and Standards .(OAQPS)/ "A Method for Assessing the Health Risks Associated With Alternative Air Quality Standards For Oaone," draft dated July 1978. The Subcommittee reviewed the methodology at a public meeting on April 19 and 20, 1979, and provides the following report. CONCLUSIONS I. The Office of AirQuality Planning and Standards is commended for recognizing the need for and undertaking the development of quantitative subjectiye_d_ecision..._ai<3s foy in_ their assessment of the .health risks of air pollutants. s II. The methodology developed by OAQPS is not ready for applieation_i_n the process o_f_ establishing air quality standards. ------- CONCLOSION I The Office of Air Quality Planningand Standardsis commendedforrecognizing the need for and undertaking the development of quantitative subjective decision aids for use in their assessment of the health risks of air pollutants. This approach recognizes that when objective information is scarce, subjective judgments by scientific experts are often essential in making quantitative estimates of risks associated with environmental pollution. The approach organizes informa- tion on subjective judgments, identifies issues about which subjective opinions ;are made and makes the analytical process of assessing risks irore explicit and open for public review. Properly done, probabilistic methodology will facilitate communication between scientific experts and decision makers. RECOMMENDATIONS 1. The Subcommittee urges the Agency to expand its efforts to develop and evaluate the•use of judgmental probabilities in the process oŁ establishing national air quality standards. While EPA should strengthen its own in-house capability for assessing risks by developing a variety of methodologies, it should also seek proposals from a number of outside experts to allow formulation and comparison of alternative approaches. This should assure that the greatest number of potentially useful proposals are considered and provide an opportunity to compare the results of EPA's proposed methodology with other ------- approaches. However,the Subcommittee emphasizes that the application of such decision .aids in the standard setting process must be avoided_until thesetools have been carefully refined and evaluated* As there is no practical way to verify conclusions which flow from the use of such methodology/ its value to regulatory decision-making depends upon the extent to which the results are believed. Since no single formulation can be demonstrated to.be "best," it is important that several be tried and compared and that an opportunity exist for the development of understanding and consensus. A clear under- standing of the concept of a methodology and the procedures for applying it, the results of alternative analytical methodologies, and the opinions of experts about the validity and reliability of a given methodology is needed to establish confidence in the results. Although the developmental work may, focus on the upcoming standard for carbon monoxide, no newly proposed methodology should be used in making the regulatory decision until credibility has been established. 2. Under no circumstances should use of such techniques become a replacement for the research needed to establish an objective data base for assessing health risks, Because they are quantitative in nature and tend to produce quantitative graphical results, decision aids that use expert probabilistic judgments tend to "look scientific," but the techniques are not a substitute for scientific fact. ------- 3, EPA should undertake or fund a major review of the experimental work addressing techniques and problems in eliciting quantitative expert opinions. There is a body of literature which identifies important limitations and biases in people1s abilities to make quantita- tive probabilistic judgments. This literature may not only assist in improving the elicitation of expert judgments but may also form a basis of legal objections to the use of quantitative decision aids. EPA's decisions on the use of methodologies involving judgmental probabilities should be made with a full appreciation of this literature. CONCLUSION II .. ' The methodology developed by OAQPS is not ready for application in the process of^establishing air quality s t and a r els. A number of difficulties have been identified in the formulation: s 1. The methodology is complex and proposes a new analytical procedure that is not adequately defined. 2, The mathematics and computer processing tend to obscure the fundamental modeling assumptions, making the analysis impenetrable to all but mathematical specialists. This is exactly what decision analysis techniques should not do. ------- 3. The conceptual basis has not been clearly described, and standardized procedures for applying the methodology have not been developed. 4. Consideration of alternative approaches has not been documented and the results have not been compared with those of alternative approaches. RECOMMENDATIONS 1. QAQPS should formulate a plan outlining how the Agency will (a) develop the proposed methodology, including standards, and protocols for application, (b) consider alternative approaches, and (c) select and establish the credibility of the best methodology, 2. OAQPS should publish, a short, easily understood description of the proposed methodology. The paper should be written for a general audience and should not rely heavily on abstract statistical concepts. In addition, the authors should submit scientific papers on the methodology to criticallyedited peer review journals. »»' 3. The encoding process' and the method of dealing with differences in expert opinion need to be improved. Meetings and interviews with experts are a critical part of the encoding process due to the risk of misunderstandings, errors and loss of credibility. The study on ozone is the only available example of how EPA would apply the proposed ------- methodology. The interviews in this example do not meet accepted standards. The authors, should familiarize themselves with the available literature on the encoding procedure. Key concepts used in the interviews need to be explicitly defined. Differences in judgments should be reviewed with the experts to see if there is a true difference or a basis for consensus. 4, The expert committee's final deliberations in arriving at a probability distribution should be a matter of public record* 5. OAQPS described two approaches to developing a "dose-response" relationship. These formulations struck a number of members of the Subcommittee as awkward. One approach used in the July 1978 report elicited opinions on the level of air pollution that would cause health effects in 1%, 5%, and 10% of. the individuals in the most sensitive part of the population. The other approach fixes the level of air pollution and asks what fraction of the most sensitive population would suffer health effects at a given level of air pollution. EPA should work on developing the latter approach, as it provides the most useful information for the decision-maker. ------- 6, Because of the considerable uncertainties on the air quality side of the model, this- portion of the model should be reformulated so that expert subjective judgments can be used there as well. The Subcommittee expressed concern about the appropriateness of a model which attempts to combine a variety of different expert judgments into a single summary finding. If this is to be done, careful' discussion and justification of the procedures applied "and the weightings used are .required. Some members would prefer a methodology which pairs health effects and air quality judgments and allows the Administrator and his staff to examine and explore the full range of resulting outcomes through appropriate summary displays. No quantitative decision aid can replace the need for a deep technical understanding of the nature and sources of the uncertainties involved.. ADDITIONAL COMMENTS The Subcommittee was asked to comment on several questions relevant to the use of the OAQPS methodology. Most of these have already been addressed. The following are comments on some of the questions not previously covered: 1, Are there Alternative___Methodologies or Modifications? It is apparent from the material presented at the meeting that there are a number of separate groups in EPA doing risk assessment. It is also apparent that these groups have little or no direct communication with each other. The Subcommittee ------- 8 urges that 'EPA develop operational linkages between these groups. It is also suggested that these activities be reviewed and selectively presented to this Subcommittee for our input and advice as to which methodologies seem to hold the most promise, which might be replicated in other sections of SPA, and when to use which proposed method and under what conditions. 2. Under What Conditions Should the Methodology be Qsed or Not Used? Encoding judgmental probabilities should be used only where it enhances comaunications between the scientific experts and the decision-makers. At one extreme, the uncertainty in the scientific data base may be so small that encoding expert opinion is not necessary. At the other extreme are cases in which the uncertainty in the data is so great that formal decision analysis approaches are not appropriate. Appropriate use lies between these extremes and will have to be judged on a case-by-case basis- 3. How Should Experts be Selected? A principal criterion is that the user (EPA) and the public have confidence in .the experts. There.are no rigid rules, but the following guidelines may be helpful. a. The experts should encompass relevant disciplines and points of view within the scientific community. The goal should be to involve experts of recognized credibility.* One member of the Subcommittee feels strongly that, insofar as practical, the experts should be free of personal interests or affiliations which might cast a reasonable suspicion about the neutrality of their judgments. ------- b. The process of identifying and selecting experts should be explicit and open. c. Each expert should be' willing publicly to acknowledge responsibility for the information and judgments he or she provides. cU Review and debate on the information and judgments should be encouraged both among the experts them- selves and among their peers in the scientific community. 4. How Many Experts^ Should be Interviewed? The Subcommittee suggests no specific number. The number will.depend upon the complexity of the issues, the variety of scientific opinion, and the different kinds of expertise that are applicable. The experimental literature on eliciting quantitative expert opinion should be consulted, and EPA should consider undertaking sensitivity tests to determine how the results might-vary with the number of experts. ------- |