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Risk assessment
Q: Does risk assessment help?
MR. COSTLE: I think it can help you organize what you know. And it can underline what you don't know, which may be more important in the ultimate judgment call than what you do. But it is just a tool to help organize our knowledge.
Q: Is that why you got into risk assessment?
MR. COSTLE: There was enormous pressure to come up with more rational defenses of the standards we were setting, and risk assessment was an emerging and promising tool. But I remember cautioning EPA scientists at the time not to put all our eggs in one basket, such as cancer risks. People would not understand risk assessment jargon, or numbers. That's why, for example, when I had to make a decision about diesel emissions, I refused to base that standard solely on cancer risks. I also looked at other reasons to worry about these emissions, such as effects on asthma. And across the board I urged the Agency to look at impacts on areas like gene structure, chromosomes, and reproductivity, in addition to cancer.
Q: Why was cancer such a huge issue?
MR. COSTLE: It was so immediately scary. Cancer statistics seemed to be going up. There had been press exposes about the rapid rise in cancer, from different causes, in different age groups. You had DES (Diethylstilbesterol) and thalidomide stories, reports of problems that are at first latent and only show up much later. That kind of publicity was guaranteed to panic people. Even if only some few panicked, however, it clearly concerned any reasonable person that maybe we -- society -- didn't know what we were doing. In a public health sense, if you wait until the bodies stack up, you have lost the game. In that way, environmental protection is more analogous to public health medicine than to curative medicine.
I think the public was also predisposed to see EPA as an actor in health issues in another respect. They understood the notion of voluntary versus involuntary exposure and risk. I experienced that very strongly as I talked to people during those years. Since saccharin was such a big debate then, I typically used a saccharin/sugar analogy to explain this concept. If a person goes to a restaurant and there is a bowl with both sugar and saccharin on the table, he knows about the controversy, and so he can choose. Where the public has a clear sense that they have a personal choice, they prefer to make it themselves. They don't want the government to do it for them.
On the other hand, that same person will walk out of the restaurant and breathe the air. In that case he can ask, "Why doesn't somebody protect me from this?" Or he'll drink tap water from the municipal supply and ask the same question. In high school chemistry, if you have a beaker of carbon tetrachloride, your science teacher can properly warn you that, if you inhale too much of the fumes, you'll keel over -- the effect is acute. However, nobody knows what the effect will be of drinking a quart of water containing two or three parts-per-million of carbon tet daily for forty years. There is no way our present science can give you such answers. Given such ambiguities, people worry. What is happening to my body? Why isn't the government protecting me?
So it becomes a much larger, more complicated debate, involving more than just the science. While the science itself is a friction point, the standard-setting process becomes an additional friction point for all the other uncertainties in public-policy making. In the end, everyone wants precision that is not there, and few people are willing to say flat out that this is a judgment call, and better safe than sorry. That is, if you can reduce risk by reducing exposure for a reasonable cost, do so because it makes more sense.
Of course, if you do this, you may make some mistakes. You may over-regulate. But if the choice is between that or waiting until you have another thalidomide incident, is that a price you're willing to pay? So you ask: What does a reasonably prudent person do in the face of scientific uncertainty? The answer is: You take reasonable precautions. That is the essence of many EPA decisions. But it is not, unfortunately, how most of these laws are written.
I was very impressed when Bill Reilly was able to establish the 33/50 program. This was do-able; you could get industry to agree voluntarily. You'd get progress in reductions, and EPA could focus on the next generation of controls that might be required, with a much more targeted scientific research effort. Whereas if the Agency had had to set standards for that list of chemicals case-by-case, nowhere near as much would have gotten done. In fact, voluntary reductions, economic swings, and the prices of energy and materials have done more to reduce exposure to chemicals in the environment than anything EPA has done or could do.
Q: Did cancer and human health concerns overshadow or in any way prevent your doing other things that you wanted to have been working on during your tenure?
MR. COSTLE: EPA activity is a learning curve. Nothing's instant. We were learning as we went along, and we really came to appreciate some things better in the third and fourth years. Our knowledge and sensitivity were forced quickly by events like Love Canal, and the realization that the tools we had to deal with such a situation were in fact very limited. And Love Canal was just one of these events. There was the Valley of the Drums, and the next dozen incidents, and the next hundred after that. I think I would have appreciated another few years to work on the research agenda.
Steve Gage wanted to create Centers of Excellence on human health, on ecology, on technology. These Centers would represent very focused programs. Essentially, EPA would say to a major university: We will support you to be the best intellectual center for ecological research that you can possibly be. You can spend half of your money however you want, to pursue excellence, to get the right people, and to build a research base. You'll create a national resource, on the model of the National Institutes. In return for our support, we want to buy half your time with some focused research that will help us solve regulatory problems that we need to address this year or the next or the following. We set aside almost half a billion dollars to start these Centers, but the Reagan administration canceled the program. I still think we were on the track to a very nicely articulated health effects research program that was appropriately balanced and less directed to chasing the chemical-of-the-week phenomenon, more systemically focused on identifying and solving longer-term needs.
So there were some frustrating areas of unfinished business when I left. Pursuing them would have probably been my first piece of advice to a new administrator.
Q: You mentioned that President Carter was an environmentalist, that you had an open door in his administration. Did you use it?
MR. COSTLE: You never use access frivolously, and I never found it necessary to take relatively small disagreements to the White House. And the administration in general knew the Agency had the President's support.