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Re: risk assessment and P2

Warren and Mike -

I have to say I both agree and disagree. Yes, risk analysis can be a
useful tool for decision-making, as long as it is recognized as that - a
tool whose limitations are recognized and whose results are placed in a
larger context of environmental decision making. The statement that risk
assessment provides a "fair and unbiased" evaluation is loaded with
assumptions about how the assessment is conducted. There are numerous
variables that often go unaddressed in risk analysis - e.g. does the
risk assessment properly calculate cumulative exposure to higher risk
populations, does it capture synergistic effects beyond the target
chemical or process, does it have a broad enough scope (e.g. exposure to
children in the home from contaminated clothing), does it look beyond
immediate exposures to life cycle impacts, etc. etc. Even when the risk
assessment is done well, and not (in Mike's words) "done to justify a
pre-determined course of action...(where)statistics have been
manipulated and the risk analyses have not been conducted properly",
there is a tremendous amount of uncertainty in any risk analysis, and,
in my experience, these confounding variables tend to get cursory

While risk assessment certainly satisfies our sense that some analysis
is better than none - and I don't advocate adopting P2 "just because" -
it is important to recognize the limitations and biases inherent in the
process. Fundamentally, the use of a risk analysis in decision making
represents a value judgement - what is the "acceptable" risk and the
concurrent trade-offs. A business contemplating a greener outlook should
conduct a high quality risk analysis, but then place that in a larger
context of its business ethics. For instance, 3M Corp phased out the use
PFOS in Scotchguard when it became clear it was a PBT chemical. I would
bet that any risk analysis would have put the actual risk from
manufacture and use of that product as very low (because of small doses,
uncertain exposure pathways, etc.) but the company decided that it
didn't want to be connected with a PBT chemical, and there were viable
alternatives. This may have been a PR move, or a timid step toward
corporate implementation of the "precautionary principle", but it is
likely that risk analysis was only one factor in making that decision.

John Katz
Pollution Prevention Coordinator
US EPA Region 9
75 Hawthorne Street, WST-7
San Francisco, CA  94105
415-947-3530 (fax)

"The views expressed above are those of the author alone, and do not
represent the opinion or policy of the Environmental Protection Agency."

                    Warren Weaver                                                                 
                    <wjw5@psu.edu>           To:     Rob Michalowicz                              
                    Sent by:                  <rob.michalowicz@sympatico.ca>                      
                    owner-p2tech@great       cc:     p2tech@great-lakes.net                       
                    -lakes.net               Subject:     Re: risk assessment and P2              
                    12/18/2001 06:37                                                              
                    Please respond to                                                             
                    Warren Weaver                                                                 

I agree completely with you, Rob. Well stated. This has been my
also. When the true costs and risks are considered in all competing
scenarios, P2 options either look good or they don't, but the process is
fair and unbiased.

Don't forget that a P2 project is only one option for a company to
when doling out its scarce resources. If a risk assessment and a
analysis show a P2 project to be the best option for the firm, then
are high (but not 100%) that this is the project that gets approved-much
higher than if you or I take a subjective "its the right thing to do"
approach. Remember, the decision maker has a dozen people whispering in
ear "Its the right thing to do! Its the right thing to do!".


>I am disappointed to hear that risk analysis my be considered to be an
>"enemy" against P2.  I do consulting work in both P2 and facility risk
>analysis and I consider both to be extremely powerful tools and
>not mutually exclusive.  In fact, in many cases my clients have taken
>actions to eliminate the use of hazardous materials based on my risk
>analyses or improved their systems for processing the hazardous
materials to
>reduce the potential impact.
>Risk analysis should be a logical, un-biased tool to help us make
>decisions.  It should not be pro- or anti- P2, but capable of analyzing
>decision based on the merits of the individual case.  Unfortunately,
>risk analyses are poorly done or are done to justify a pre-determined
>of action.  In these cases, the statistics have been manipulated and
>risk analyses have not been conducted properly.  In these cases, the
goal of
>making better decisions has been defeated.
>The use of risk analysis should not be discarded because some are using
>incorrectly or abusing it.  Our goal should be to continue to improve
>risk analysis techniques so we make better decisions.
>Robert Michalowicz. P.Eng.
>Chem Process & Environment Inc.
>tel.  (416) 236-5377
>fax  (416) 236-9355
>----- Original Message -----
>From: "Janet Clark" <clarkjan@turi.org>
>To: <p2tech@great-lakes.net>
>Sent: Monday, December 17, 2001 2:35 PM
>Subject: risk assessment and P2
>> Hi P2techies,
>> I would like to ask if there is a way we can talk about how
>> manipulation affects our work in P2. It may be that this message
should be
>> on the P2policy list, but I think this technical list has the
>> grounded expertise needed for these questions. I will move offlist
>> this topic if asked.
>> Here is the question: In the battle between p2 and continued use of
>> -- which takes place in academia, government, trade associations,
>> facilities and communities -- do you accept decisions largely based
>> existing risk studies?  Risk analysis has not prevented alien
chemicals in
>> our bodies, and doesn't seem to address unknowns such as hormonal,
>> accumulative, synergistic, immune suppressing, vulnerable population,
>> second generational effects.
>> P2 advocates continuous improvement, but companies move slowly and
>> this with acceptable risk numbers in their cost benefit analysis of
>> alternatives.  These "qualified" numbers get an undeserved life of
>> If you believe something is missing, should we be doing more work in
>> educating consumers, insurers, and other stakeholders about unknown
>> surface a more cautious approach to decisionmaking?  Our local media
>> reluctant to carry anything about P2. Is the media responsible for
>> nation's less progressive perspective on toxic risk than the European
>> community? What are your strategies for getting news coverage?
>> Janet Clark <clarkjan@turi.org>
>> Associate Director for Information
>> MA Toxics Use Reduction Institute
>> University of Massachusetts
>> One University Ave.
>> Lowell, MA  01854-2866
>> Tel 978-934-3346, Fax 978-934-3050
>> **********************************
>> http://www.turi.org
>> http://www.p2gems.org
>> http://www.turi.org/Greenlist
>> **********************************