r
EPA's risk assessment culture
Terry E Yosie Environmental Prorection Agency Washington,D.C. 20460 For many years management analysts have noted the existence of organizational or corporate culture: the system of shared values and beliefs that allows the employees, structures, and control systems of an organization to carry out a common mission (I). Organizational culture is seen in such areas as IBM's emphasis on customer service and in Toyota workers singing the company song. Less attention is devoted in the professional literature to organizational culture in the public sector, especially within regulatory agencies, even though culture plays a large role in in526 Environ. Sci. Technol., Val. 21. NO.6, 1987
fluencing the outcome of government decisions. This article offers some preliminary observations, hypotheses, and discussion about EPA's organizational culture. In particular, it focuses on some of the organizational values and dynamics that influence the practice of risk assessment at EPA. Risk assessment plays an important role in EPA's regulatory processes. It serves to integrate and express uncertainties in scientific data, aids in identifying research gaps, and provides a technical basis for policy decisions. Moreover, risk assessment helps define additional policy options, and it heavily influences ultimate policy choices. The purpose of this article is not to identify or evaluate all of the existing or poten-
tial factors that comprise EPA's risk assessment culture but rather to comment on some selected factors that greatly influence the practice of risk assessment.
Structural factors Statutory criteria. Among the structural factors that influence risk assessment at EPA are the criteria the agency must use to comply with the mandates of its various authorizing statutes. For example, the Clean Air Act, as traditionally interpreted by EPA and as upheld by the Supreme Court, does not provide for the consideration of costs in setting primary National Ambient Air Quality Standards (NAAQS); instead, EPA must set health-based standards that encompass an adequate margin of safety. In practice, this has led the
0015936x187/M)210526$01.50~0Q 1987 American Chemicd Sociely
1
agency to set standards below levels at which adverse health effects can occur. The amendments to the Safe Drinking Water Act, on the other hand, require the EPA administrator to establish maximum contaminant levels that protect the public health from exposure to pollutants. Criteria used in setting these levels include assessments of available technology, methods of treatment, and other techniques. Cost must be considered as well. The Federal Insecticide, Fungicide and Rodenticide Act imposes a risk-benefit balancing test that allows manufacturersto register pesticides that “will perform [their] intended function without unreasonable adverse effects on the environment” (2). EPA translates the goals and language of these and other statutes into
criteria that are used to evaluate the risks of specific pollutants as a basis for reaching regulatory decisions. What is absolutely clear to anyone trying to implement these statutes is the statute-tostatute variability in terms of factors that can be considered in the decisionmaking process. Complicating these efforts are two additional characteristics of the existing statutes. Many environmental laws, such as the Clean Air Act, Clean Water Act, and Safe Drinking Water Act, f e cus on one medium or pathway through which pollutants adversely affect public health or the environment. These laws have influenced the past and current structure of the agency through the creation of assistant administrators for each medium. This development has exacerbated the normal problem of bureaucratic turf The question often arises of which medium deserves the greatest application of resources. As a result, the agency frequently directs scientific and other issues into a medium-specific mindset. A related problem concerns the conflicts that arise between specific statutory programs. For example, Congress passed both the Resource Conservation and Recovery Act (RCRA) and the Superfund law essentially to protect drinking-water sources from chemical pollution. This is also a stated purpose of the Safe Drinking Water Act. RCRA and Superfund programs, however, command a large portion of agency resources and its policy development effort. There is a dichotomy between the goals and needs of these programs and the purposes of drinking-water standards that were developed to comply with laws that govern objectives other
also weigh a larger number of adtninistrative, economic, legal, scientific, and policy issues than ever before in reaching regulatory decisions. There is an expanded system of internal and external scientific review, public comment, and Office of Management and Budget review. Offsetting this more complicated and sophisticated level of analysis, however, is the fact that it is virtuallv imwssible to eet anvthine done rapidly.’ When William Ruckelshaus returned as EPA administrator in 1983. one of the first issues he confronted ‘was the revision of the particulate matter NAAQS. After listening patiently to staff briefings on the air quality criteria document, the elaborate peer review of the scientific data base, and discussions of population exposures in different regions of the country, Ruckelshaus reminisced about how he had promulgated the initial standards in the early 197Os., In those days, the process took months instead of years, far fewer p p l e were involved, and the setting of particular levels for the standards could be called a highly educated guess. The public accepted the decision, and subsequent (and more sophisticated) analysis has confirmed the reasonableness of those earlier decisions. Ironically, as the agency has gotten older, the work force has gotten younger. Many of the personnel who joined EPA upon its formation have retired, will soon retire, or have departed for financial, professional, or other reasons. In addition, the experience curve has suffered as the agency work force was reduced by 27%-from 14,874 to 10,844-between fiscal years 1981 and 1983. The number of employees now
than hazardous-waste cleanup. Bureaucratic aging process. Another structural element that influences decision making, and that does not receive enough attention, is the fact that EPA is getting older. One characteristic of this development is the evolution of more rational, formalized procedures for making decisions (3). Within EPA these procedures have resulted in analytical effortsthat are more numerous, more sophisticated, and of higher quality than before. Senior officials must
stands at 14,165, or 31% a b v e the 1983 levels (4). Most of the newly hired personnel are young and talented, but they have virtually no institutional experience or memory. Also, they are not likely to stay at EPA for very long. Like the Harvard MBA who expects to be a corporate vice-president by age 35, many of the new members of the staff are ambitious but impatient. And because of the lack of institutional memory, there is a constant need to reascend the learning curve.
- . -
Environ. Sci. Technol.. Vol. 21. No. 6. 1987 527
Skills mix. Another structural factor is the professional background of EPA officials. Donald A. Schon writes in his book, The Reflective Practitioneer, that “certain ways of framing problems and roles come into good currency . . . [that] bound the phenomena to which [professionals] will pay attention . . . and thereby set the directions in which they will try to change the situation” (5). Phrased another way, professional training equips a person with a particular set of analytical tools, but it also acts as a prism that influencesthe interpretation of data and the degree to which data might support professional values and standards of quality. In observing the behavior of EPA officials, professional norms sometimes play as significant a role as adherence to the goals or norms of the bureaucracy. For example, an EPA research scientist publishes to enhance his personal stature in the scientific community as well as to advance the technical basis for regulatory decision making. The economist advocates an expanded use of benefits analysis to advance this methodology within the economics profession. An additional factor, however, is the need to comply with Executive Order 12291, which requires the preparation of a Regulatory Impact Analysis and Office of Management and Budget Review for major regulations. One criterion used to define a major regulation is economic impact in excess of $100 million. In preparing this article I conducted a survey of the professions represented in senior policy-making positions at EPA headquarters. Although no direct correlation should be inferred for professional affiliation and the advocacy of a particular policy position, it is important to note the underrepresentation of certain professions. No senior EPA official has a degree in toxicology; only two have degrees in pharmacology and zoology. The most frequently represented disciplines are engineering, chemistry, law, economics, and political science. One implication for the practice of risk assessment is the continuing need to assist senior officials in understanding the policy implications of technical data and methods that are used to estimate risks. When a new study is published on the carcinogenicity of tetrachloroethylene, for example, the technical staff must educate those occupying more senior positions on highly esoteric issues that include the protocols for conducting such a study, the significance of the reported results, and the extent to which the results confirm or challenge existing policy options or decisions. These efforts consume a great deal of staff time. 528 Envimn. Sci. Technol.. Voi. 21, No. 6, 1987
L
Moreover, they create a degree of tension between the need to classify or synthesize scientific data for policy makers (or for Congress, the media, or the public) and the need to capture the noise. or subtleties in the data to satisfy a purely technical audience. Sometimes the data conform to the categories regulatory agencies use to classify and evaluate them, but often they do not. Even if all senior EPA policy officials had doctorates in scientific disciplines, however, many of the significant problems facing the agency would remain because science and risk assessment are only part of the totality of issues addressed in regulatory decision making. Nevertheless, there should be a better match between the problems facmg the agency and the current skills mix within various offices. Recent steps indicate a growing recognition of this problem. The EPA ’Raining Institute, created in May 1986, for example, offers courses in a number of disciplines concerning a variety of environmental issues. In addition, agency task forces are currently developing plans to upgrade the technical capabilities of the in-house staff. Finally, as EPA risk assessors practice their craft, they face a never-ending challenge to stay abreast of technical advances within the scientific community. This presents a challenge: Because relatively few resources are available for training or professional develop ment, agency staff frequently must play
catch-up. The good news, however, is that EPA staff frequently generate technical advances. For example, the agency’s research program on total human exposure combines methodological innovation with policy relevance. In addition, members of the staff are attempting to develop better tools for assessing risks across environmental media from multiple sonrces. In such instances, an important challenge is to gain acceptance of this work from the scientific community. The track record is mixed, in part because some of the in-house advances stay there, but awareness of the need for peer review and publication has increased substantially. Process characteristies Some of the characteristics of EPA’s risk assessment process not addressed here include the use of agency staff rather than contractors to prepare risk assessments, the sometimes unclear boundaries between risk assessment and risk management, the incremental nature of the risk assessment process, conservatism in risk assessment, and how different EPA offices characterize scientific uncertainty. These issues merit separate treatment. However, three characteristics that are addressed here are the shifting influence among the offices that prepare assessments, the expanded use of external scientific advisors, and the search for consistency
in the development of risk assessments. S h i f t i i patterns of influence. During the past decade the body that has exercised the greatest influence over risk assessment practice within EPA has been the Cancer Assessment Group (CAG) of the Office of Research and Development. Both the directors and the staff of CAG exhibit a number of qualities necessary to achieve organizational leadership. The centralization of technical skills, the cohesiveness and stability of the office leadership and staff, and the development of client offices within EPA that use CAG analyses as the scientific basis for regulatory decisions are just three factors that have established this group as a major force within EPA. Other areas are the codification of the CAG risk assessment a p proach through EPA policy statements and guidelines, its leadership within interagency forums and councils, its communication with extramural scientific and policy analysis communities, and its development of networks of support with these communities. During this period CAG has prepared quantitative risk assessments for many of the compounds at the top of EPA’s regulatory agenda, among them acrylonitrile, arsenic, benzene, coke oven emissions, dichloromethane, and trichloroethylene. Between 1976 and 1983 CAG assessed the carcinogenicihi of at least 150 compounds (6). In the past several years, howeve other centers of risk assessment have evolved within EPA. This has occurred for a number of reasons, one of which is that, like any successful organization, CAG has a position to defend. This condition attracts critics, both within and outside EPA. The National Academy of Sciences expressed concern that CAG blurred the distinction between science and policy in its assessments. Committees of EPA’s Science Advisory Board have criticized the rigidity of its interpretation of data and have called for a revised format for risk assessments and for greater variation in the expression of uncertainties in risk estimates. Industrial groups also have challenged what they see as CAG’s overly conservative risk assessment assumptions. At the same time, there has been increased pressure from within EPA to generate more assessment documents, and the directors of regulatory offices have expressed concern over the ability of CAG staff to meet deadlines. As a result, CAG has engaged in more firefighting exercises and has had less time and fewer resources to devote to developing revised cancer guidelines, guidelines for noncancer health end points, and alternative risk assessment methodologies. Not until 1984, for example,
did agencywide task forces, which included some CAG staff, propose a revised guideline for carcinogenicity, new risk assessment guidelines for chemical mixtures, developmental effects, exposure assessment, and mutagenicity. As the roles of scientific analysis and risk assessment have become more important in decision making, many of the regulatory offices within EPA have hired or expanded their own scientific staffs. In addition, EPA’s regional officials have hired, or are planning to hire, new scientific staff members to improve their ability to assess site-specific risks. As a result, these oftices are becoming less dependent on CAG or at least are more able to challenge the technical assumptions and interpretations found in CAG‘s assessments. Consequently, the risk assessment process within EPA has become more competitive. This has led to a practice of what political scientist Gordon Wlock calls “bureaucratic free enterprise,” which produces a leakage of authority in the organization such that pressures encountered by lower level officialsoften are unrelated to the needs and objectives of those above (3. Consumers of risk assessments, like consumers in the marketplace, now have more opportunities to shop around. But instead of producing customer satisfac-
an incentive, or at least no disincentive, for inviting external participation. Among the reasons EPA officials seek external peer committee review are the need to improve the scientific quality of risk assessments and a desire to receive the equivalent of a scientific seal of a p proval. This provides a shield that these officials can use to deflect the criticisms of adversaries within EPA, from industry or environmental groups, or from the Offce of Management and Budget. Senior managers also need confirmation of the quality of their subordinates’ work, and they fear the inevitable severe criticism should a technically inadequate document be used in rule making. These and other incentives exist, and their significance should be recognized. Since 1983, the advisory committee system has become more formal, and the use of such committees, chiefly through the Science Advisory Board, has greatly expanded. In lune 1985, the administrator issued a memorandum directing a broader use of the Science Advisory Board to enable it to review at least 50 scientific issues each fiscal year. In 1981, the board conducted 10 scientific reviews; in fiscal year 1986, 65 such reviews were conducted (8). External peer review has become a growth industry at EPA.
EPAk risk assessment culture has sometimes create0 opportunities for external p u p s to manipulute the &ciswn-making process by intewening for or amins particular assessments.
tion, EPA’s risk assessment culture has sometimes engendered staff distrust or created opportunities for external groups to manipulate the decision-&ing process by intervening either for or against particular risk assessments. External peer review committees. Any discussion of EPA’s peer review system must account for the incentives EPA officials have to submit risk assessments to committees of external scientists for independent review. Most of EPA’s scientific advisory committees are affiliatedwith the Science Advisory Board. Why should agency officials consider submining the technical bases of regulations to a group of scientific advisors who are not directly accountable, whose advice cannot be controlled, and whose timetable for providing advice will likely differ from the regulatory timetable? These ofticials must believe there is
What are some of the implications of this practice? On the positive side, the involvement of scientific advisors has demystified the regulatory decisionmaking process by clarifying the relationship between scientific data, risk assessment, and standard setting. Scientific committees provide advice largely in a public arena, not just to comply with the requirements of the Federal Advisory Committee Act but also to grant the public additional opportunities to observe committee activities or to comment directly on relevant technical data. As a result, there tend to be fewer surprises, both in judging EPA’s intentions and in the reactions of environmental and industrial groups to policy options. The quality of many scientific assessments that have undergone such review also has improved. The result is that EPA has emerged with a much stronger Environ. Sci. Technal.. Vol. 21, NO. 6 , 1987 529
scientific basis on which to develop and defend regulations. External review of agency assessment documents also aids in identifying areas for future research which, if carried out, would further strengthen the scientific basis for decsion making. The mere fact of such reviews creates an incentive for EPA staff members to integrate their work; as advisory committee members become more involved in the agency’s operations they ask pragmatic questions and solicit information on the relationship of risk assessment activities conducted by a number of EPA offices. At the same time, independent peer review by advisory committees has shortcomings. The American Chemical Society and the Conservation Foundation stated in their joint monograph on peer review in regulatory agencies that the use of peer review makes the process longer and more cumbersome (9). Second, scientific advisory committees sometimes address, either intentionally or inadvertently, issues that cross scientific or policy boundaries, thus creating a ricochet effect that introduces new or expanded limitations on the range of decision-making options and authority (3). This can result from the inexperience of panel members, from their desire to influence policy choices, or, in the words of Robert Crandall and Lester Lave, because of “scientists’ alienafrom the chaotic, pressured world
butadiene, and dichloromethane. Similarly, many agency offices have used different formats and definitions in preparing assessment documents. Many documents address hazard evaluation or dose-response relationships, whereas others characterize risk by inclusion of exposure assessments. Different groups will use different terminology in referring to such issues as hazard and risk. For example, “unit risk estimate’’ in some EPA documents is “potency estimate” in others. These and other inconsistencies are often noted by scientific advisory committees and other external parties and can become sources of contention. More senous, however, is that differing scientific assessments create the potential for conflicting regulatory decisions. Search for a new culture Perhaps the most important point to be made about the state of risk assessment at EPA is that the events of the past 10 years have laid the foundation for a new risk assessment culture. Of equal importance is the recognition by senior EPA managers that this transformation is taking place and that its Structure and content must include their direct participation. Many elements of a new culture already exist that can be adopted readily with no need for a change in the mission or structure of the agency and without requiring the
me mere fact of such reviews creates an incentive for EPA hff members to integrate their work; as adviso~~ comm&ee nembers become more involved in the agency’s opemtions, they ask pragmatic questions.
of the regulator, with its need for timely answers” (lo). In general, however, as scientists and regulators gain more experience in working together they have developed more efficient methods for conducting scientific review and have clarified the nature of their roles and responsibilities.
Search for consistency Different EPA offices have periodically issued their own risk assessment documents for the same pollutants. This practice arose because of differing regulatory schedules and requirements, but it also is the result of the desire of various offices to exercise more direct control over the preparation of assessments. For example, EPA produced several reports on dioxins, and a number of assessments exist for asbestos. 530 Environ. Sci. Technol., Vol. 21, No. 6. 1987
addition of new resources. Some of the more prominent features of this new culture are discussed below. Multimedia risk assessment. In its 1984 report, “Controlling Cross Media Pollutants,” the Conservation Foundation concluded that “US.environmental-protection laws seek to control pollutants as if they remain in the same medium to which they are initially released. But many pollutants are discharged into more than one medium, and few remain in a single medium. They cross and recross boundaries, change form, and have harmful effects in [other] media . . . Under a crossmedia perspective, an environmentacontrol agency assesses the risks caused by discharges into different media and develops the most efficient and effective mix of control requirements to re-
duce the assessed risks” (11). This statement is representative of the thinking of senior EPA officials, and it is reflected in a number of programs: EPA is now assessing the distribution of risks posed by various sludge disposal options, from land treatment to incineration at sea. It is evaluating the public health risk posed by incineration of municipal wastes. Direct inhalation of air pollutants is at issue, but also of concern is uptake of the same pollutants through the food chain. The agency is developing methodology to identify and assess the major sources of human exposure across media in a series of case studies to be conducted in Baltimore, Denver, Philadelphia, and the Santa Clara Valley in California. Mediating or integrating structures. In his book, Democracy and Mediating Structures, James Luther Adams writes that all successful mediating structures depend on the creation and maintenance of “an efficacious social will in a more or less unified enterprise” (12). There must be a role for creative dissent, but undergirding the entire structure must be mutual trust that will persist through periods of change or stress. A major challenge in creating a new risk assessment culture at EPA is to design mediating or integrating structures to collect, analyze, and, above all, reconcile alternative scientific assumptions at the staff level and to do the same for alternative policy options at the policy level. The framework for such structures already exists. In 1984, the administrator and deputy administrator established the Risk Assessment Forum, a group of senior staff scientists charged with evaluating scientific issues across the agency. The forum collects and analyzes information on public health issues, conducts special studies, reviews scientific issues that relate to decision making for several regulatory programs, and recommends guidelines to formalize or modify existing risk assessment practice throughout EPA. A similar group is the Risk Assessment Council, made up of senior scientific and policy officials. This group is charged with identifying policy and risk assessment issues, resolving interoffice differences on such issues, and commissioning special studies. The council also has formal responsibility for overseeing the operation and activities of the Risk Assessment FONm. When agency scientists cannot reach agreement on risk assessment issues, the council has authority to determine the best way to resolve the differences. A third body is the Risk Management Council, which functions similarly to the Risk Assessment Council.
New methodologies. EPA is placing increased priority on the development of innovative methodologies to expand the range of analytical tools that can be used in risk assessment. Several areas serve as examples: EPA has sponsored a National Academy of Sciences workshop on methodologies to incorporate metabolic and pharmacokinetic information on specific substances into quantitative dose-response assessments.
environment (13).The scope of public concern is universal; it applies to hazardous-waste sites in New Jersey, to pesticide applications in Kansas, and to the issuing of permits to biotechnology companies in Monterey County, Calif. Technology is on trial in the court of public opinion, and so are the people who develop and regulate it. The agency is taking a number of actions in an attempt to characterize the public’s perceptions about various
tute of Technology, Cambridge, Mass. 02139; and Edward W.Lawless, Midwest Research Institute, Kansas City, Mo. 64110. The views expressed in this article are the opinions of the author and do not repre sent the official views of the Environmental Protection Agency. A version of this paper was presented at the 191st National Meeting of the American Chemical Society, Atlantic City, N.J., April 15, 1986. References ( I ) Utm!, B. “The Corporate CulNre Vultures, Fortune, Oct. 17, 1983; pp. 66-72. 12) In Current Issues in U.S. . Ennviron&ntal , Portnev. I! R.Policy: Portney, P: R., Ed.; ~
~
~
~~~
~~~
~
~
~
~
Resources for lhe Future: Baltimore, 1978;
%re must be a rdefor creative &sent, but unhgi~,. the entire saudure must be mutual aust that willperski thmugh perhi3 of sttvss or change.
pp. 118-29. (3) Downs, A. Inside Bureaucracy; Little, Brown: Boston, 1967. (4) “1988 Budget in Brief”; Office of the
Compuoller; EPA: Washington, D.C., lanua n 19R7~ --, ( 5 ) Schon. D.A. R e Reflecrive Pmcririoneer; Basic Bwks: New York, 1983; p. 309. (6) Risk Assessmenr in the Federal Governrnenr: Managing rhe Process; National
A totA human exposure methodology has been developed to evaluate human activity patterns in specific microenvironments. This effort is coordinated with the development of new monitoring technologies and the verification of exposure assessment models. Research has begun on the survival, growth, and genetic transfer of biotechnology products. The development of risk assessment methodologies is important for at least two reasons. First, because so much of its decision making rests on a technical foundation, EPA‘s credibility is enhanced when it seeks opportunities for and demonstrates competence and leadership in advancing the risk assessment state of the art. Second, the development of new methodologies creates opportunities for working toward the objective of scientific consensus, not only withii EPA but also with the scientific conununity.
Risk cnmmunication Because the abatement of risk involves making rational technical judgments in concert with selecting from alternative value judgments, it is important for the staff of EPA to understand the economic, psychological, and social implications of regulatory decision making. It is also essential that citizens understand the nature and degree of environmental risks that confront them. During the past 25 years there has been a dramatic rise in public awareness of environmental risk. A major consequence of this development is the increased burden on the generators and regulators of hazardous substances to explain the sources and degree of risk to human health and the
sources of risk. EPA officials are also trying to articulate the agency’s actions to reduce risks. Such efforts include the trend toward greater involvement of the professional community of decision analysts. The agency is sponsoring meetings to allow groups of Pennsylvania citizens to express their perceptions concerning indoor radon exposures. Risk communication conferences will be used to explain to representatives of the media, Congress, environmental and industrial groups, members of the scientific community, and individual citizens how EPA uses scientific data in reaching regulatory decisions. New methods of communication are being explored as well. What is clear is that EPA is at the beginning of its risk communication learning curve. It will make mistakes and miss opportunities. However, accumulated experiences will, over time, provide a sharper focus for both the conceptual and the administrative needs of the agency in implementing an effective risk communication program. This in turn will stimulate the professional community of risk assessors, managers, and communicators to develop new data and methodologies for the central purpose of building public consensus on the best methods for solving environmental problems (14). Risk communication can become into a form of mediation, with built-in checks and balances that will lead the public and the public servant to understand and accept their roles and responsibilities.
Acknowledgment This article has been reviewed for suitability as an ES&T fealure by Ken Sexton, Health EffectsInstitute, Cambridge, Mass. 02142; Dale Hattis, Massachusetts Insti-
Academy Press: Washington, D.C., 1983; p. 107. (7) ’Mock, G. Rhe Politics of Bureaucracy; Public Affairs Press: Washington, D.C., 1965; pp. 167-70. (8) “Report of the Director of the Science Advisory Board for Fiscal Year 1986”; Science
Advisory Board; EPA: Washington,
D.C.,
1986. (9) “Issues in Peer Review of the Scientific
Basis for Regulalory Decisions”; American Chemical Society: Washington, D.C., 1985; p. 13.
(IO) Crandall, R. W.; Lave, L. B. In 7he Scie n t $ ~ Basis of Health and Safely Regulation; Crandall, R. W.; Lave, L. B.. Eds.; Brwkings Institution: Washington.
D.C.,
1981; p. 17.
(I I ) “Controlling Cross Media Pollutants”; Conservation Foundation: Washington.
D.C., 1984; pp. 1, 6. (12) Adams, 1. L. In Democracy and Medioting Srnmures; Novak, M.. Ed.; American Enterwise Institute for Public Policv Rercaroh: Warhinglun. D.C 1980: pp. 4-5.
.
(13) S l o v c . P. Firchholf B ; Lshtenrtein. S . Pwc. R. Sur. London Ser A 19RI. 3R6. 1734.
Covello, V.; von Winterfeldt, D.; Slovic, P: “Risk Communication: An Assessment of the LiteraNre on Communicating Informs-
(14)
tion About Health. Safety and Environmental Risks,” draft preliminary report; EPA: Washington, D.C., 1986.
’Terry E Yea- .I.r of EPAs Science Advisory Board. In addition, Yosie has published on the role of professional groups in developing public policy and on the use of scientijc information in policy development. He also is deputy cachairman of the U.S.-Soviet Bilateral Environmental Agreementprojecr, which is the inregrating mechanism for environmental activities berween the rwo countries. Y.ICC.YI
Environ. Sci. Technol., Vol. 21. No. 6. 1987 531
