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Ranking risks Dear Editor: The feature article on risk/hazard-based ranking of pesticides ("Ranking Pesticides by Environmental Impact," July 1995, p. 324A) raises an important consideration for comparative risk and ranking. Risk assessment, and thereby comparisons of risk or hazard among agents of exposure, must be based on good science for valid decision making (cf. Seiler, E A. and Alvarez, J. L., Technology: Journal of the Franklin Institute, 1994, 331A, 53-58). As the feature was more a news story focusing on the work of William Pease and others than a technical article, the basis of the models cited weren't presented. Ecologist Joe Kovach is quoted as saying, "It can come down to some number that makes sense of the world." I don't disagree, but unless there is rigorous adherence to good science, there is opportunity to incorporate errors that can produce an aberrant result for decision making. The concept of hazard ranking based on information at hand is certainly well intentioned, but it (1) must be based on calibrated and validated models, (2) may introduce unacceptably large error compared to the risk/hazard being estimated (Seiler, F. A. and Alvarez, J. L., Technology: Journal of The Franklin Institute, 1994, 331A, 83-95), and (3) may produce a spurious relationship (induced correlation) when ratios are used for ranking (cf. Use and Abuse of Statistical Methods in the Earth Sciences, International Association for Mathematical Geology Studies in Mathematical Geology No. i, W. B. Size, Ed., Oxford University Press, New York, 1987). I hope that ES&T will consider presenting a more thorough report on the specific models and methods cited in this article in the future. LARRY R. FROEBE International Technology Corp. Irvine, CA 92714-6260
8 A • VOL. 30, NO. 1, 1996 / ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS
Response Researchers involved in the development of multiattribute hazard ranking models for pesticides share Froebe's concerns about "good science," but we find we must be realistic about what data and assessment models are available. Once one evaluates the toxicity and exposure data available for hundreds of pesticides, it becomes apparent that they are of widely disparate quality and rarely sufficient to support comprehensive human health or ecological risk assessments. The output of hazard ranking models is not intended to be an actual risk estimate, but is instead a rough guide for farmers to choose less harmful pesticides or regulators to target potential problems. The question is whether ranking is useful in the face of the inescapable uncertainties affecting a system's inputs. From our perspective, the appropriate standard for this evaluation is whether it has advantages over approaches currently used to make these choices. Prior to Cornell's development of the EIQ index, farmers had no pesticide cross-compound guide to the attributes indicative of potential risk. Targeting in the regulatory arena is similarly uninformed, typically focusing on a single qualitative attribute like carcinogenicity. WILLIAM PEASE University of California-Berkeley Berkeley, CA 94720-7360
Correction The feature published in April 1995, "Status of Ambient Measurement Methods for Hazardous Air Pollutants" by R. Mukund et al. (pp. 183A-187A) contained an error on page 183A. The second sentence of the second paragraph should read: "This survey found that only 126 of the 189 HAPs have methods that are reasonably established for ambient air measurements, although not all of these methods are EPA-approved or well-demonstrated for ambient monitoring."
