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19 EPA J. 35 (1993)
Relating Risk Assessment and Risk Management

handle is hein.journals/epajrnl19 and id is 35 raw text is: - POINTS OF DEBATE

Risk Assessment

and Risk

Should risk assessment be considered distinctly separate from risk
management? A 1983 National Academy of Sciences report
concluded that it should and government agencies since then
have generally operated on that assumption. Recently, howtver,
some experts have been reevaluating the relationship between the
two. Presented here are two views on the controversy.

Complete separation of the two processes is a misconception
by Sheila Jasanoff

hould risk management (what we
wish to do about risk) be allowed
to influence risk assessment (what
we know about risk)? The very idea is
anathema to environmental policy
makers who came of age in the 1980s. It
is like asking whether politics should
control science. We are reminded of
Galileo bowing to his inquisitors or of
Lysenko delivering to Stalin the genetics
that served the ideology of the Soviet
state. Trained to think of science as
value-free, we believe that the inevitable
result of subordinating knowledge to
politics must be the corruption of both.
Closer to home, EPA watchers may
recall the sorry events of the early 1980s
that helped give rise to the doctrine of
separating risk assessment from risk
management. In one especially
unfortunate incident, the Agency's Office
of Pesticides and Toxic Substances
exempted formaldehyde from
designation as a priority chemical under
Section 4(f) of the Toxic Substances
Control Act, even though this widely
used compound had been definitively
shown to cause cancer in rats. Legally
(asanoff is professor and chair of the
Department of Science and Technology
Studies at Cornell University.)

and scientifically flawed, the underlying
analysis seemed to have been unduly
influenced by the concerns of the
formaldehyde industry. It was a blatant
case of risk management objectives
overriding the risk assessor's impartial
evaluation of scientific data. Later EPA
administrators were determined not to
see this error repeated.
Judgment, moreover,
must remain sensitive to
the policy context.
_ n
The specter of improper interest
group influence was one of the concerns
that guided the National Academy of
Sciences' (NAS) authoritative study of
risk assessment practices in the federal
government. In its Red Book report of
1983 (so named because of the report's
red cover), the NAS espoused the now-
classic position that regulatory agencies
should clearly separate risk assessment
from risk management. Even the
perception that risk management
considerations were influencing risk

assessment, the Red Book authors
asserted, would diminish the credibility
of the assessments themselves and of
management decisions based upon them.
But careful practitioners of risk
assessment have recognized from the
start that theirs is not a purely scientific
activity. Indeed, risk assessment is often
described as an art rather than a
science. This formulation emphasizes
that risk assessment, like any artistic
endeavor, requires the exercise of
subjective judgment. It cannot be done
by mechanically following the rules.
Judgment, moreover, must remain
sensitive to the policy context.
Risk assessment operates in the
ambiguous borderland between
systematic observations of the physical
world (science) and politically
accountable decisions about public health
and welfare (policy). Even the NAS
report recognized that such a process
must be conditioned by factors deriving
from both the scientific and political
domains. The choices involved in risk
assessment, the report states, rest on a
mixture of scientific fact and consensus,
on scientific judgment, and on policy
The need for judgment in risk
assessment is often attributed to scientific

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