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GUEST EDITORIAL The emperor’s new clothes In the field of environmental decision-making methodology, the newcomers are risk assessment and risk management. Although much has been written about the field, we ought to ask whether the risk assessmentrisk management diad is in fact a new approach. The story of the emperor’s new clothes is applicable here: The need to believe can create its own reality. A recent National Academy of Sciences report recommends that the risk assessment and risk management components be separated as much as possible within regulatory agencies. The purpose is to avoid contamination of the scientific aspects of risk assessment with the policy considerations implicit in risk management. , Did the NAS report take a cue from the Spanish Inquisition, in which investigation was performed by the ecclesiastical staff and management was delegated to the secular staff? If so, it should be remembered that decision making ultimately was vested in the ecclesiastical branch. In the risk assessment-risk management approach, decision making is certainly not left to the scientists. In fact, it is unclear where this responsibility lies. Current regulatory experience Seems to favor continuous communication between scientists and regulators for effective environmental decision making. In a 1970 editorial in Chemical & Engineering News (Nov. 30, p. 9), “Someone Put a Number on It,” Abel Wolman noted that standards development was designed as an orderly process for “summing up scientific information, epidemiologic inquiry, empirical evidence, and value judgments.” The participants in the process of setting standards were professional societies and government agencies. This allowed a linkage to form among scientists, professional society representatives, and regulatory agency employees. Wolman saw the problem of the 1970s as abandonment of the linkage and the orderly process in favor of public relations goals of stringent standards. In an article in Civil Engineering (June 1965, pp. 7071), P: H. McGauhey also recognized the need for linkWl393BW8810921Ml.m/0@ 1986 American Chemical Society
ages in the process of setting standards by defining environmental quality in quantitative terms. He noted that the standards and regulatory processes work only when there is tacit acceptance of a great deal of folklore and uncertainty regarding quantitative measures. This acceptance requires collaboration among all parties to the regulatory process-the scientists, econe mists, social scientists, regulators, and legislators. There have been notable advances in the scientific basis of environmental decision making, but an appreciable uncertainty remains. The folklore component of policy and management is still with us. An artificial compartmentalization of the participants will make the product neither more certain nor more accurate. A review of the older literature on quantitative measures and the regulatory process does lead to some interesting conclusions. The emperor’s new clothes do exist, even though they are not really the latest fashion, and any claims to the evolution of new methodology are open to dispute. The elements of uncertainty in risk management are only partly solvable through current analytical procedures. The judgments beyond methodology require free discussion and communication. Scientists do not need protection from the difficulties of policy, law, regulation, or even implementation.
Monis ShignUrn is a professor of environmental health at the Universiiy of North Carolina af Chapel Hill. His work is in the areas of food safety and program ewluarion. Environ. SA. Technol.. MI. 21,No. 1. 1987 3
