Setting Priorities for Envirobental Policv rl
There is a growing realization that the demand for funding to correct U.S. environmental problems will soon outstrip available resources. The estimated cost of remediating Superfund hazardous waste sites ranges from $32 million to $80 billion. Areas such as ozone depletion, global warming, the protection of endangered species and wetlands, toxic air pollution, carcinogenic pesticides, and urban smog are competing for the same financial resources. In response to the imbalance in the supply and demand for national funds, several political constituencies are calling for the use of risk assessment as a tool to prioritize research and budget needs. President Bush’s recently issued FY 1992 budget calls for “risk-based budgeting” for implementation of numerous health and environmental laws. William Reilly and the EPA Science Advisory Board advocate establishing environmental priorities on the basis of relative risk and assert that comparative risk analysis may be useful in the process. They recognize that such analysis offers a framework in which to organize information about complex problems, allowing policy analysts to allocate resources on the basis of scientific judgment rather than political expediency. As with every methodology, risk assessment has its limitations. Critics charge that risk analysis is not sufficiently precise to be used for prioritization. Risk analysis is imprecise, but that does not in and of itself disqualify it for use in prioritization. Risk analysis is the accepted regulatory method for setting drinking water and clean air standards, limits on releases from incinerators, and acceptable levels of dioxin in fish. These applications require far more precision than does prioritization. Rather than criticize the lack of precision, we must call for more focused biological research to reduce the uncertainties and to improve the credibility of risk analysis. Given the central position of risk analysis in our current regulatory framework, it is difficult to believe that a more focused national effort is not under way to identify and prioritize critical biological and environmental research that would reduce uncertainty in risk analysis. National Academy of Sciences President Frank Press recognizes the political realities of limited resources and challenges the scientific community to rank research needs within fields so that limited 0013-936W92/0926-215503.00/0 0 1992 American Chemical Society
funding can be allocated accordingly. William Reilly echoes this sentiment: “Science can lend a measure of coherence, predictability, authority, order, and integrity to the often costly and controversial decisions that must be made.” Risk analysts need to answer this challenge by prioritizing the most pressing research needs in environmental policy. Most risk-related research is currently focused on issues that will not reduce uncertainty in analysis procedures. A reallocation of existing research dollars toward finding short-term solutions to specific risk-related questions [such as the level of human exposure at hazardous waste sites, the existence or nonexistence of a threshold for dioxin, or improvement of interspecies extrapolation) could vastly reduce uncertainties and greatly improve the credibility of risk analysis. Our nation does not have sufficient financial resources to address all of its environmental problems. Money is being spent ineffectively in some areas while high-risk situations go unaddressed. We call on environmental scientists to actively work on a national effort to prioritize our environmental problems and to reduce uncertainty in risk analysis procedures. This can be accomplished only through focused research and a better understanding of the biological and environmental mechanisms involved. To paraphrase John Graham, director of the Harvard University Center for Risk Analysis, despite the difficulties involved in applying risk assessment to gain insight for prioritization, the process is still useful-and it is certainly better than the alternatives. The central issue is not whether to use risk analysis for prioritization. It is whether, in the face of our nation’s numerous needs, we can afford to continue spending millions of dollars on projects that do not effectively reduce risk to health or the environment.
+f? b t y ” Curtis C. Trovis is director of the Center for Risk Managenlent at the Oak Ridge National Loborotory in Oak Ridge, TN. Bonnie P. Blaylock is a research associate with the Center for Risk Management. Oak RidAe National Laboratory. Environ. Sci. Technol., Vol. 26. NO.2. 1992 215