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Fw: risk assessment and P2


For every course of action there is a risk.  I think that a risk analysis
accompanies every decision made, whether it is consciously recognized or
not.  When we don't formalize that risk analysis, we make conclusions about
the risk based on perception.  Our perceptions will be subjective and
perhaps erroneous, leading us to poorer decisions.

When we disagree about a potential course of action, we have all made our
own risk analysis regarding the decision (formal or not) and what we are
disagreeing about are issues such as: what is the potential damage?, how
likely is it?, how much confidence do we have in the data?, what assumptions
are appropriate?, what are the risk measures?, what is an acceptable level
of risk?  A good risk analysis should be transparent and it should clearly
show the data, assumptions, and methods used in the risk analysis.  Parties
of interest can then follow a good risk analysis and can identify areas of
disagreement.  Uncertainty and sensitivity analysis is an important part of
a good risk analysis.  John, when you express the limitations of risk
analysis, I think what you are expressing are the limitations of some of our
risk analysis methodologies.  I very much agree.  We have much work to do to
improve our risk analysis methodologies.  But, we can never get away from
doing risk analysis.

Even the precautionary principle is 'risk analysis' thinking.  In risk
terms, if we are not confident about the accuracy or extent of our data, our
confidence limits in our calculated risk values are lower.  Therefore, we
may need to take a conservative approach until we are able to obtain better
data.  In that case we make decisions based on damage levels and likelihoods
that are in the high range of our estimates.

Rob Michalowicz, P.Eng.
Chem Process & Environment Inc.

----- Original Message -----
From: <Katz.John@epamail.epa.gov>
To: "Warren Weaver" <wjw5@psu.edu>
Cc: <owner-p2tech@great-lakes.net>; <p2tech@great-lakes.net>; "Rob
Michalowicz" <rob.michalowicz@sympatico.ca>
Sent: Wednesday, December 19, 2001 11:50 AM
Subject: 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
> attention.
> 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
> 415-972-3283
> 415-947-3530 (fax)
> katz.john@epa.gov
> "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:
>                     owner-p2tech@great       cc:
>                     -lakes.net               Subject:     Re: risk
assessment and P2
>                     12/18/2001 06:37
>                     PM
>                     Please respond to
>                     Warren Weaver
> I agree completely with you, Rob. Well stated. This has been my
> experience
> 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
> consider
> when doling out its scarce resources. If a risk assessment and a
> financial
> analysis show a P2 project to be the best option for the firm, then
> chances
> 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
> his
> ear "Its the right thing to do! Its the right thing to do!".
> Warren
> >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
> definitely
> >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
> better
> >decisions.  It should not be pro- or anti- P2, but capable of analyzing
> any
> >decision based on the merits of the individual case.  Unfortunately,
> many
> >risk analyses are poorly done or are done to justify a pre-determined
> course
> >of action.  In these cases, the statistics have been manipulated and
> the
> >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
> it
> >incorrectly or abusing it.  Our goal should be to continue to improve
> our
> >risk analysis techniques so we make better decisions.
> >
> >Robert Michalowicz. P.Eng.
> >Chem Process & Environment Inc.
> >rob.michalowicz@sympatico.ca
> >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
> statistical
> >> 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
> specific,
> >> grounded expertise needed for these questions. I will move offlist
> with
> >> this topic if asked.
> >>
> >> Here is the question: In the battle between p2 and continued use of
> toxins
> >> -- which takes place in academia, government, trade associations,
> >> facilities and communities -- do you accept decisions largely based
> on
> >> 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,
> and
> >> second generational effects.
> >>
> >> P2 advocates continuous improvement, but companies move slowly and
> justify
> >> this with acceptable risk numbers in their cost benefit analysis of
> >> alternatives.  These "qualified" numbers get an undeserved life of
> their
> >own.
> >>
> >> If you believe something is missing, should we be doing more work in
> >> educating consumers, insurers, and other stakeholders about unknown
> risk
> >to
> >> surface a more cautious approach to decisionmaking?  Our local media
> is
> >> reluctant to carry anything about P2. Is the media responsible for
> our
> >> 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
> >> **********************************
> >>