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Risk assessment
[October 1, 1993]
Q: It occurs to me that in the '70s, a number of environmentalists were concerned that risk assessment was a means by which industry watered down environmental legislation, watered down environmental mandates - I've read some material that seemed to imply that. What changed during the '80s and then during your tenure in the later '80s that made risk assessment something that the Agency was using to further its environmental mandate, its environmental goals?
MR. REILLY: There was an attitude towards risk assessment, and still is, in some environmentalist circles and in some parts of the Congress, some important ones, that regard risk assessment in about the same way that the traditional environmental establishment regards dilution as a means of pollution control. That is, you work down to the level at which you will tolerate death and disease and set a restriction there, set a tolerance or a pollution standard there, that isn't too costly. I can recall during the Thomas Administration at EPA there was a very negative exchange on public radio, as I recall, where someone alleged that at EPA people were actually trying to calculate the number of acceptable deaths due to a particular carcinogen. The attitude reflected in that radio program's excoriation and caricature of Thomas' approach to risk posits the possibility, ultimately, of zero risk and regards zero risk as the ideal towards which we should work. That has tremendous appeal. There is no question but that one would like to live in a society that is risk-free, or at least render that part of it to which we are involuntarily exposed free of risk - the chemicals that come on our food, the pesticides that are used on products that we consume, the air that we breathe and the water we drink.
I think that the concept of risk assessment and then risk management, that is, of trying to determine a level of practical achievable control, gradually gained currency as a consequence of two things. First of all, the Agency dealt with many more problems than it used to, as a consequence of a whole plethora of legislation that was added to its responsibilities in the '70s and '80s - the Toxic Substances Control Act, the Resource Conservation Recovery Act, the Superfund Law. The result of this was to cause even the most idealistic and protective of EPA staff to realize, we can't do it all. We have got, ourselves even, to make some allocation of our resources, given the fact that there's more for us to do than we can do. The Congress never came through with sufficient funds, nor did Administrations typically request them, truly to allow all of the responsibilities carried by that Agency to be borne.
Secondly, the technology of detection advanced very significantly. Within a space of a few years, we went to the possibility of detecting not just parts per million but parts per billion and even in some areas, parts per quadrillion, as detectable, though admittedly trace, amounts of particular chemicals. This began to pose the problem of, as Senator Moynihan once said to me, "Well, knowledge is sorrow, really." To the degree that we understand that there are trace amounts of carcinogens on our food from pesticides, or even in natural products like coffee or peanut butter, we ourselves have to acknowledge that we are making these choices and tradeoffs of the kind that the public radio criticized.
I think this throws everything into somewhat greater relief. It certainly requires a more mature accommodation of reality. It also reminds us that some of these pollutants are facts of life. They are in the environment, many of them irrespective of human alteration and manipulation. Ultimately, you will find, for example, arsenic, which is a naturally occurring phenomenon, in common food products, once detection is fine-tuned enough. That forces you to acknowledge that what you need is some reasonable method for predicting levels of real impact on humans so that you can protect people to an adequate standard. The ideal is to ensure through regulation that such inevitable risks are negligible, i.e., that they would not over a lifetime of anticipated exposure in a real world situation result in more than one excess cancer death in a million people. Zero risk is a chimera, a beckoning illusion. To try to achieve it would consume unjustifiable amounts of resources, and entail forgoing much progress. Tolerating a certain trace level of pollutant in certain circumstances, is more than offset by gains to health that you can get with the freed-up resources. We have probably way over-emphasized cancer, for example, in regulating for pollution control in the United States, to the neglect of things that cause neuro-toxic problems in fetuses, developmental problems, brain development concerns that have nothing to do with cancer.
I think that when you realize that in some instances you would be better able to protect society against a larger problem in gross if you didn't deploy a disproportionate amount of your resources on what is a much smaller problem, it causes you then to get into the realm of risk assessment and risk management. The regulator, then, is in fact, however, doing nothing different from what you and I do every day. We decide to walk as opposed to take the car someplace or ride a bicycle or maybe do something a little more dangerous like ride a motorcycle or scuba dive. The difference, of course, is that some of those risks we choose for ourselves. There is a popular preference that government should try to absolutely eliminate those risks we do not have direct control over, that people don't voluntarily choose. It can't be done.
Risk assessment, I think, has gained currency as a consequence of a very large set of responsibilities that forced prioritization. Secondly, the discovery that we cannot provide perfect security for everyone at all times. Again, as Senator Moynihan once put it, "Well, life really is about risk and it ends badly."