Policy Study

Seeking Safety in a Dangerous World

Environmental Risk Reduction Framework for Policymakers

Executive Summary

Today’s environmental concerns often involve invisible threats, such as the threat of global warming, the threat of ozone depletion, the threat of increasingly lower levels of air pollution, the threat of lowdose exposure to chemicals, and so on. Environmental problems today are often so subtle that they can only be quantified using epidemiological techniques or sophisticated computer models. While previous problems could often be controlled by relatively simple and low-cost technological solutions, the environmental issues that remain tend to be very complex, are as much behavioral as technological, and are often very expensive to address.

Architects of environmental policy in the 1960s and 1970s usually couched problems in terms of protecting the “general health.” Almost everyone could be portrayed as a potential beneficiary of an environmental “clean up.” Today, however, environmental initiatives are increasingly justified on the basis of protecting only a segment of the population, usually the most vulnerable, and especially children. In this context, some have proposed a risk-focused decision framework.

But a risk-focused framework for environmental policy poses new challenges, especially for low-level risks. The proliferation of safety measures aimed at small risks makes it difficult to compare potential safety investments. Making such comparisons is further complicated when complex mitigation measures are required, when risk-reduction measures only offer benefits to a small percentage of the population, and when other portions of the population might experience increased risks through unintended consequences or the indirect effects of regulations. Such complications make it difficult to insure that resources used to address risks will produce the desired outcome without introducing new risks or by shifting risk from one person or avenue of life to another.

Making sound public-policy decisions regarding environmental safety measures requires a net-benefit framework for portraying both the nature of environmentally conveyed health risks and the consequences of taking action to reduce them. It also requires an easily understood framework for choosing a risk-reduction strategy. Such an environmental-safety investment framework can help decisionmakers make sensible choices regarding risk policy. It can also help individuals evaluate whether they’re getting a net benefit from taxpayer resources invested in environmental risk reduction.

One solution to this problem might be a process of comprehensive comparative risk assessment, in which all risks and risk-reduction interventions are numerically assessed and ranked. But a comparative-risk approach has problems of timeliness and complexity, compounded by the subjective nature of risk. The “precautionary principle,” favored by some environmental activists, offers an even less-attractive strategy for reducing risks, because it ignores the majority of relevant criteria that include realistic depictions of uncertainty regarding risks and intervention effects.

An alternative is a case-by-case evaluation of proposed risk-reduction interventions against a set of touchstones to insure that a proposed risk-reduction intervention is likely to:

  • Save more lives on net, than it will take; and
  • Outperform the natural risk-reduction benefits of leaving resources to circulate in a dynamic, marketbased, knowledge-building economy.

Such a framework requires:

  • A scientifically rigorous assessment of the best estimate of risk that reviews pertinent risk information and has transparent and meaningful peer review;
  • A holistic evaluation of potential safety investments that considers risk-reduction, risk-shifting, risktrading, and opportunity costs of investment; and
  • A method for evaluating whether a resilient (adaptive) or interceptive strategy is more likely to secure a net risk reduction.

When applied to two recent, high-profile proposals to reduce environmental risk through regulation (the revised National Ambient Air Quality Standards of 1997 and the Kyoto Protocol of 1998), such a framework suggests these proposed risk-reduction measures are likely to do more harm than good.

The National Ambient Air Quality Standard revisions fail a simple test of providing a net health benefit when considerations of risk trading, risk shifting, and opportunity costs are considered.1 The Kyoto Protocol also comes up short. Persistent uncertainties in our understanding of climate change suggest that taking interceptive actions to forestall the negative consequences of climate change are likely to cause near-term increases in risk; offer only questionable long-term reductions in risk while absorbing limited risk-reduction resources; and invite significant unintended consequences.