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Environmental Risk Management Decision-Making in a Societal Context

Posted on: Wednesday, 15 March 2006, 12:00 CST

By Power, M; McCarty, L S

ABSTRACT

Recent studies point to the need for improved understanding of environmental management frameworks designed to combine qualitative public and quantitative technical inputs in decision-making processes. Flux in public perception and concern about risks imply frameworks must be iterative in nature and incorporate a variety of assessment triggers in the form of decision points. A conceptual model is proposed here to explain the de facto operation of standard risk analytic frameworks within the broader sociopolitical milieu of public policy. The model is presented as a decision flow diagram that emphasizes setting environmental management goals based on societal input and the formulation of decision criteria for selecting management actions to achieve those goals. Prospective and retrospective decision control points operate to select management options that, respectively, avoid or reduce actual or predicted effects. Feedback loops that modify risk management outcomes are identified. Technical and scientific inputs (i.e., risk analysis) are assigned an essential information role within the framework and are responsible for informing the management process with the results of appropriately conducted and reviewed investigations. The proposed model is intended primarily to indicate how environmental risk management decision-making and associated technical assessments may be influenced by social pressures. It is hoped this understanding will lead to analytical transparency and better public communication of the environmental implications of policy options.

Key Words: environment, risk, decision-making, public policy.

INTRODUCTION

Numerous studies examining environmental risk point to the need for improved understanding, monitoring, and decision-making in environmental management. These include the Carnegie Commission, the National Research Council, and the Ecological Society of America (CCSTG 1992; NRC 1993, 1996; Christensen et al. 1996). Many scientists have further argued that scientific practice should dominate the identification, analysis, and solution of environmental problems (Mayer 1997). Others have not (Ludwig et al. 1993). Most of the early attempts to construct frameworks for guiding action on environmental problems stressed the role of scientific investigation (e.g., USEPA 1992; Suter 1993) and paid little attention to the importance of social assessments. Demands for stakeholder participation in decisionmaking, recognition that non-technical analyses can influence policy, and the need for improved communication have highlighted the inadequacy of past and current approaches to the development of broadly acceptable environmental solutions (NRC 1996; Royal Society 1992; McCarty and Power 1997). Cumulatively, these concerns indicate that science-based environmental assessment activities must recognize they operate within a sociopolitical milieu and act to support effective environmental management in the public interest. The apparent dichotomy of needs, scientific and technical rationality on the one hand and social subjectivity on the other, is a consequence of the respective levels at which risk assessments are conducted, reviewed, and implemented (Burgman 2005). While decision-making is evidence- based, social decision-making is not similarly constrained.

Environmental decision-making framework development and application often yields differences in opinion and information between, and among, professionals and concerned citizens (Baram 1973). Experience has shown that ongoing research and monitoring will not necessarily resolve those differences (NRC 1996; Royal Society 1992). This is because of the long gestation period associated with some problems (e.g., risks associated with occupational contaminant exposure and cancer), the difficulties associated with establishing clear causal relationships (e.g., greenhouse gases and climate change), and the controversies associated with determining trade-offs between the risks and benefits of actions (e.g., agricultural pesticide use). Continuing differences in opinion highlight the trans-scientific nature of many environmental issues and the need to make decisions with imperfect information (Power et al. 1995). Furthermore, the growing awareness of the implications of uncertainty has made command and control environmental decision-making largely unacceptable to the public (NRC 1996; Presidential Commission 1997).

EXISTING FRAMEWORKS: ROLES AND RESPONSIBILITIES

To develop an appropriate model of environmental decision-making it is necessary to consider the roles of science and public interest and the respective ways in which they may be influenced, or influence, the dynamic of the decision-making process. Recent advances in the development of risk-based decision-making frameworks have recognized the need for information-related iteration and/or the ways in which perceptual understanding of a given risk issue can influence the goals of a risk assessment (NRC 1996; Presidential Commission 1997; USEPA 1998). Many frameworks have also explicitly noted the need to be iterative in nature and open to a variety of societal influences. The need for iteration and stakeholder input is incorporated in the risk management component of most frameworks (Power and McCarty 1998) and is best represented as a decision flow diagram (see Figure 1). Features include: setting environmental management goals based on societal input, formulating decision criteria (a priori whenever possible) for selecting actions to achieve those goals, and the use of detailed information to inform, evaluate, and update management action (McCarty and Power 1997). The essential role of science (i.e., risk analysis or assessment) within most frameworks is to inform the management process with the results of appropriately conducted and reviewed investigations, rather than to dictate a course of action. The role is not a trivial one and has been identified as one of the critical unmet needs of society in the evolving debate about environmental health and policy (NRC 1996; Lubchenco et al. 1991; NSB 1997).

Figure 1. A generic environmental decision-making model for describing the evolution of environmental assessment and management decisions. Decision control points focus public input on issue assessments (yes/no as to whether to initiate or revisit a risk management process) and are gateways for iteration in overall decision-making. Action assessments comprise the various technical assessments used in the evaluation of multiple action options to achieve case-specific risk management goals.

Technical assessments of an environmental issue alone, however, are not sufficient to constitute appropriate analytical and/or deliberative support for decision-making (NRC 1996; Presidential Commission 1997; UKDOE 1995). In addition to meeting requirements for quality and replicability, investigation must be directed toward answering the right questions. This latter requirement points to an important role for public participation in defining the issues to be analyzed. To address the proper questions, decision-making frameworks must include input from other technical assessments (e.g., economic, legal, political, engineering, and social) that describe and define key environmental management goals expressed either explicitly, or implicitly, in public debate of an issue.

The loss of objectivity for environmental decision-making from including public concerns and other assessments is more apparent than real. Science is neither objective nor neutral in a decision- making context. Biases exist in framing research questions (NRC 1996) and in the choice of analytical assumptions when completing analyses (Shrader-Frechette 1991). Although science can often demonstrate the probable consequences of management alternatives, it cannot determine the options that should be considered in the decision-making process or select between them in terms of social desirability. This limitation implies that the environmental risk assessment process needs to be embedded within a decision-making process dominated by iterative feedbacks that allow for social influences (Power and McCarty 1998). Under such circumstances science provides information, not solutions (Ludwig et al. 1993; Lubchenco 1998) that help policy-makers and the public to better understand the consequences of differing policy choices (UKDOE 1995; SASNZ 1999).

SOCIETAL INFLUENCE AND DECISION CONTROL POINTS IN AN ITERATIVE DECISION-MAKING MODEL

The problem definition phase is critical to the successful implementation of the management component of any environmental decision-making framework. Problem definition is not necessarily the arcane exercise typically described in the literature involving detailed discussions between designated risk managers and assessors (USEPA 1992; Moore and Biddinger 1995). The needs and interests of both decision-makers and affected parties must be considered by the process. These include technical issues (e.g., toxicity, bioaccumulative potential, and persistence) and social issues (e.g., the definition of valued ecosystem components). Social concerns cannot be ignored because fears over possible management actions will find voice in the many form\al and informal parallel assessments of risk conducted in economic, political, and social circles.

Results from problem formulation analyses frequently influence public opinion to the point where they are able to circumscribe risk management activities and may increase conflict in, or reduce acceptance of, the management process as a whole (NRC 1996). In this context science has an essential obligation to address issues in proportion to their perceived societal importance and to clearly communicate the knowledge necessary to inform individual or collective decision-making processes. Furthermore, the fact that societal concerns can circumscribe science-based assessments suggests that the latter should be viewed as operating within the confines of broader societal decision-making loops, as depicted in Figure 1.

Societal pressure can be exerted on an environmental decision- making process in advance of specific knowledge of the possible consequences of a proposed management action to avoid, or reduce, its potential effects. Such pressure constitutes a prospective decision control point and can trigger, or modify, the management process (Figure 1, A loop). Societal pressure can also be exerted after specific knowledge of the effects of management action or inaction become obvious. Such pressure represents a retrospective decision control point that can also trigger, or modify, the risk management process (Figure 1, B loop). Such phenomena are best explained in the context of the avoidance and effects control feedback loops depicted in the conceptual environmental decision- making model of Figure 1. As is the case with any model an initial test of its utility is its ability to explain existing observations. Possible combinations of loops within the suggested model include five patterns descriptive of the majority of environmental risk contingencies:

1. Avoidance or effects control pressures prove completely effective on first use (single A or B loop). This is most likely to be the case for routine, well articulated environmental problems whose consequences are confined to local scales, that is the placement of sediment traps between surface disturbance and water interfaces during road construction or community-based development decisions to protect small wetland areas. Such decisions are made using existing regulatory guidance and technical assessment protocols and will often be supported by a plethora of technical information. Furthermore, the public will also often be conversant with the issues and procedures for making the decision.

2. Pressure for avoidance control could loop repeatedly through the risk management cycle before an effective action is agreed on and implemented (multiple A loops). The pattern is typical of larger, more complex regulatory decisions involving multiple stakeholders where the focus is on the refinement of selected management options. The decision-making process is often dominated by uncertainly because of a lack of information and/or disagreement over the acceptability of regulatory objectives. Furthermore, the consequences of a "wrong" decision are not known, or easily estimated, and there may be little agreed upon conceptual understanding of the technical nature of the problem. Suggested use of irradiation for improving food safety, the siting of hazardous waste treatment/storage facilities, and the health and environmental implications of genetically modified crops are examples.

3. Pressure for avoidance control could loop once, or repeatedly, through the risk management cycle and fail to result in the selection of an action eliminating all perceived, or real, environmental effects. As a result of initial action inadequacies, pressure for effects control would lead to one, or multiple, iterations of the risk management/effects avoidance control cycle (A loop(s) leads to B). The pattern is typical of the "learning by doing" phenomenon associated with many resource and environmental management problems (Ludwig etal 1993) where the information base changes with time. This pattern of decision-making is widely reflected in the increasing comprehensiveness of regulatory standards with time. An example of the pattern is the move from aqueous-based concentration standards to the inclusion of sediment guidelines in the assessment of water quality under the United States Clean Water Act.

4. Pressure for effects control could loop repeatedly through the risk management/effects control cycle in an attempt to refine the selected control option before arriving at one satisfying the gamut of possible social and technical concerns (multiple B loops). The pattern is typical of debates over large-scale environmental problems where evidence of effects exists but causal linkages are difficult to establish, or where information is imprecise and conflicting in its implications. Examples include concern over endocrine-active compounds that can interfere with developmental or hormonal systems and the health significance of the detection of low levels of contaminant mixtures in humans.

5. Experience with the effects control/risk management cycle could lead to adaptive refinement of the avoidance control/risk management process. This is the experiential transfer phenomenon seen in many environmental management debates often dominated by the "look what happened elsewhere" argument that motivated the development of more extensive pesticide screening and monitoring regulations in light of experiences with DDT (B loop(s) leads to A). A second example is provided by discussion about the U.S. Environmental Protection Agency (USEPA) revised reference dose for methylmercury, a decision that did not go unchallenged. In the broader context of public health, competing risks from the consumption of substitute foods, potential medical consequences of dietary changes, and the social and economic ramifications of restrictive fish consumption advisories the USEPA decision was questioned and the technically agreed-on reference dose was revised (Egeland and Middaugh 1997).

These five decision-making iterations are clearly separate and different from iteration pathways within the risk management box in Figure 1. There iteration reflects technical discussion about decision criteria formulation/application, data refinement and interpretation, and the articulation and implementation of management action options. As long as the post-decision evaluation of a risk management outcome remains acceptable the original decision stands. However, if there is social rejection of the decision or the subsequent development of sufficient doubt about the decision, the decision-looping iteration process described earlier comes into play, triggering the need to revisit the technical assessment encapsulated in the risk management box of Figure 1.

DISCUSSION

The model proposed above for explaining the dynamics of the environmental decision-making process recognizes that pressures for avoidance and effects control influence, and are influenced by, management action. The model further recognizes that it is unlikely that public opinion and pressure will remain temporally constant or consistent. Concern over environmental issues will periodically increase, or decrease, as pressures for avoidance or effects control rise and fall. Social, political, and technical monitoring continue, either formally or informally. As more detailed information becomes available concerns sufficient to invoke a reexamination of decisions may occur. This implies any management action can, at best, be viewed as acceptable only over a limited time horizon. As a consequence, even an informed environmental risk management decision may be challenged. For example, while airborne particulate standards have improved urban respiratory health, research on the potential effects of smaller particulate matter has led to demands for even more stringent standards (from 10 to 2.5 m). Calls for improvement have occurred despite the lack of scientifically validated cause and effect linkages or established mechanisms of action for reported health concerns (Kaiser 1977).

In addition, case-to-case differences arising from the particulars of a specific problem are likely. Differences between largely identical cases associated with the expression of local preferences for action, or varying perceptions of risk, may be common. As a result, the management outcomes of analogous situations are unlikely to be identical. In that sense the model does not describe a deterministic process. Rather it describes a dynamic process combining the varying influences, desires, and activities that constitute the whole of environmental regulation and how they may combine to produce a prescription for action. Continued use of an embedded risk management framework (i.e., Figure 1) also provides a basis for increasing the consistency of evaluations and judgments and, as a consequence, may lead to more equitable risk management actions for diverse or related risk issues.

The structure of the suggested decision-making model highlights a shortcoming of existing environmental practice. Assessors and managers often attempt to respond to the dual challenges of identifying a problem and selecting the most appropriate management alternative with a single analysis. Although similar, the activities entailed in meeting either challenge are distinct and should be carried out separately. The model presented in Figure 1 resolves this problem by classifying these sequential and noninterchangeable activities as issue assessments and action assessments.

Issue assessments are ongoing, occur at the decision control points in Figure 1, and will determine if adequate concerns exist to trigger the prospective A loop or retrospective B loop depicted in Figure 1. Furthermore, the outcome of an issue assessment is a simple dichotomous (Yes/No) decision. Although not presented in detail here, issue asses\sments use the same basic structure, terminology, and processes for the technical assessments that are presented in the action assessment portion of the risk management framework (e.g., NRC 1996; Royal Society 1992; McCarty and Power 1997; Presidential Commission 1997; SASNZ 1999; Moore and Biddinger 1995). Issue assessments do not attempt to determine what should be done. Instead issue assessments focus on judging whether an issue is of sufficient concern to warrant proceeding to the risk management process, where a management option is selected for implementation. The information for issue assessment need only be sufficient to select between the "yes" or "no" options.

Action assessments are where scientific and other technical processes can play a vital role in informing the attempts of risk management (Figure 1) to select from among available policy options. These range from maintenance of the status quo to complete clean- up, restoration, or cessation of emissions. Typically three or more options for action will be considered (status quo, remediation, cessation) but there is no limit to the number of options that may be included (Egeland andMiddaugh 1997). For effective decision- making the information provided by a risk assessment must be rigorous enough to allow option ranking. Some information inputs (social and/or political) may be qualitative. Others, like economics, engineering, and science, will generally provide semi- quantitative or quantitative evaluations (SASNZ 1999).

There is a tendency among the technical disciplines to provide very detailed data and analyses simply because it is possible. In decision-making, however, information need only be sufficient to address the decision criteria being employed and there is no requirement that such information be exclusively quantitative (Royal Society 1992; SASNZ 1999). Excessive, or irrelevant, information may confuse the debate. Accordingly, technical specialists must take particular care to exercise judgment when providing information about the likely consequences of differing management options.

A distinct advantage of the separation of issue and action assessments in the decision-making process oudined in Figure 1 is that it provides a clear basis for identifying when it is appropriate to incorporate precautionary activities. The definition of the Precautionary Principle formulated as Principle 15 of the Rio Declaration on Environment and Development (UNEP 1992) is widely accepted. It states:

In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing costeffective measures to prevent environmental degradation.

There is no formal role for the Precautionary Principle in issue assessments, although a precautionary approach at this juncture would entail allowing a relatively low level of public concern on an issue to trigger a full risk management action assessment. The use of a low level of public concern as the criterion for initiating an action assessment ensures that the Precautionary Principle will play an important part in determining the action assessment agenda, but will prevent lack of scientific or technical certainty about possible effects being used as an excuse for banning an activity prior to the completion of a full action assessment. Thus, whenever there are controversial discussions about the acceptability of maintaining the status quo, when conducting a retrospective analysis, or permitting a new chemical or activity, when conducting a prospective analysis, the debate will be framed in the context of all feasible risk management options rather than the more restrictive and confrontational dichotomous allow/disallow choice.

The described model can be employed at different management levels. Science may be used at a macro-level to support the selection of a broadly applicable regulatory policy. The Clean Air Act in the United States, the adoption of greenhouse gas emission reduction guidelines in Europe, and the no net loss of habitat policy in Canada are examples of such use. The framework may also be employed at a microlevel to select site-specific regulatory actions (e.g., the detailed actions required to remediate a contaminated site or locate a municipal landfill). The processes that constitute the framework may be invoked irrespective of whether a conscious choice is made to engage the decision-making process. Preferences for maintaining the status quo, or for by-passing the risk management process altogether, will last only as long as social pressures for effects control will allow.

CONCLUSIONS

Although the context here is environmental, the proposed decision- making model is generic enough to be applied to a broad spectrum of risk-related issues. Discussion of workplace health and safety issues, exposure and cancer risks, and the potential risks of technological innovation share the attributes that require placing environmental decision-making activities within a sociopolitical context. The requirement to make decisions in the face of uncertainty and recognition that emotion and social and political issues will mix with fact to influence choice.

Limited resources for addressing environmental issues, however, mean scientific and technical analyses will continue to play an important role in the development of methods illuminating environmental risks. Scientific and technical disciplines can provide a means for consistently organizing and analyzing disparate information, but cannot solve the risk-related problems posed for ecosystems by human actions. Should regulatory and technical experts adopt the conceptual model expounded herein, improved public and regulatory understanding of management decision-making processes are expected. In addition, the technical information fed to decision- makers is likely to be better framed to address the problems at hand, with the result that public risk communication will improve.

Faced with imperfect information, regulators have little choice but to "act as if and proceed, right or wrong, with the implementation of guidance designed to reflect a variety of current information sources and social concerns. Inevitably, this guidance will be subject to socially driven control pressures related to the natural evolution of technical knowledge and public perceptions. Technical experts must realize that their own utility for environmental decision-making is premised on the notion that the values, views, and perceptions driving environmental management debates are those assigned by affected individuals and interest groups and not by the quantity or quality of technical advice. Failure to recognize this point will marginalize even the best technical advice.

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M. Power1 and L. S. McCarty2

1 Department of Biology, University of Waterloo, Waterloo, ON, Canada; 2 L. S. McCarty Scientific Research and Consulting, Markham, ON, Canada

Address correspondence to L. S. McCarty, L. S. McCarty Scientific Research and Consulting, 94 Oakhaven Drive, Markham, ON, Canada, L6C 1X8. E-mail: lsmccarty@rogers.com

Copyright Taylor & Francis Ltd. Feb 2006

Source: Human and Ecological Risk Assessment

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