Dealing with Risk

The notion of managing environmental risk lies at the heart of Part IIA. The overall risk-based nature of the system implies that it is anticipatory (it does not have to wait for the actual manifestation of harm) and that it is not arbitrary in its approach (for example, by focussing regulatory action solely on particular past land uses or at some particularly point in time, such as when the land is being sold). But the concept of risk, and risk management, permeates throughout Part IIA—in the detailed text, in the overall process, and in the choices that are made in the system. 

The most immediately apparent area where this concept of risk drives the Part IIA system is in the core definition of contaminated land, set out in Section 78A 

19 Paragraph A.9, Circular 2/2000, Annex 3 although this definition was, in turn, borrowed from wider DETR publications on environmental risk—see later footnotes. 

This clearly introduces the idea of possibility or likelihood which can be related to the scientific terms probability or frequency . It also builds in the concept of consequences —i.e. significant harm or pollution of controlled waters . 

The Pollutant Linkage Concept. A further concept within the definition—the contaminant-pathway-receptor approach—is elaborated in the statutory guidance. This concept has, in recent years, come to represent the predominant intellectual framework for risk assessment in general20 21 and has underpinned the development of contaminated land technical thinking. Unless a particular receptor could be harmed, through a defined pathway, by an identified contaminant, then land cannot be considered to meet the definition of contaminated land. 

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Margolis, H. (1996) Dealing with Risk Why the Public and Experts Disagree on Environmental Issues. Chicago, University of Chicago Press. 

According to the Directive, an active substance cannot be used in a PPP unless it is included in an EU positive list. The Directive also requires very extensive risk assessments for effects on health and environment to be carried out, before a PPP can be placed on the market and used. In 1992, the European Commission started a Community-wide review process for aU active substances used in PPPs within the EU. Based on scientific assessments, each applicant had to prove that a substance could be used safely regarding human health, the environment, ecotoxicology and residues in the food chain. This program will be completed by 2008. From the end of 2003, the European Food Safety Authority (EFSA) deals with risk assessment issues and the European Commission retains the risk... 

BULL I only have one problem with what you said, Junk, and that was when you attempt to judge the level of risk using the Ames test results. You cannot compare this water with that water. I do not think there is any way that we are going to deal with risk with the Ames test or use it in any kind of absolute terms now or in the future. I think the only thing you are going to be able to do is use it in a relative sense to judge the effectiveness of a treatment process within a plant. It will not serve as a standard that can be applied nationally in any meaningful way. 

Another factor that helps define the cleaning strategy is recognizing the type of cleaning situation we are faced with relative to what is going to be manufactured next in the equipment. I like to tell people that you ve got to learn to look downstream in cleaning validation in order to determine what you might contaminate and thus determine the element of risk. Some situations are simply more risky than others and we must be able to study and deal with risk. We must be able to accept a certain level of risk because it is always with us and unfortunately cannot be driven down to absolute zero. 

As a conclusion of this section about the role of uncertainty analysis and description, it is worth noting that despite all the work and effort, a scientifically adequate analysis and description of uncertainty will lead to some discomfort and might introduce an element of communication conflict. This is a consequence of the state of uncertainty and should be considered. Some people are tempted not to show the quantified and especially the unquantified uncertainties, but that does not solve the underlying problem. Since transparency is an important attribute of openness and trust, both will help to increase the confidence of those involved in dealing with risks. 

Of late, I have been disappointed by the consensus opinion which appears to be growing regarding dealing with risk assessments. From information in the media and discussions with contemporaries and agency representatives, I detect an opinion that suggests society is not ready to deal systematically with... 

In many cases, we must take action and make decisions prior to regulations being issued which deal with risk in specific areas. By necessity then, we need and use a system that reflects our corporate environmental goals and also allows guiding the... 

According to the review by Buccini 2004, most agreements, programs and initiatives deal with risk management for hazardous chemicals (a discussion of the... 

These factors include the ethnic and socioeconomic characteristics of populations as well as the structure and history of communities that must deal with risk concerns. For example, a company town may react quite differently than a rural agricultural village or an inner-city neighborhood to information about risk from an environmental chemical. 

Two additional steps that may be inclnded as part of a QRA inclnde sensitivity analysis and the evaluation of risk reduction options. Sensitivity analyses are often used to evaluate the influence of various data components and assumptions of the QRA. One should always remember that the risk analyst is dealing with risk estimates, and, in order to use these estimates properly, it is essential that the potential extent of uncertainty or key assumptions that are a major influence on the risk results be known and understood. 

To deal with risk, mostly they measure it using variability (or volatility), which is incorrect in almost all engineering project cases, as is explained later. They diversify by adding stocks to the portfolio. 

Toxic Substance Control Act (TSCA) Since 1976, the EPA has been given the authority to gather information on the toxicity and hazardous nature of individual chemicals. Chemical producers are required to supply information dealing with risk assessment of proposed products 90 days before proposed manufacture or import. Included in this information is chemical fate testing, environmental effects testing, and health effects testing. 

The problem in pharmaceutical safety is different there is risk in prescribing a potentially unsafe drug, but there is also risk in not prescribing the drug (the patient dies from their medical condition) a risk/risk situation. The risks and benefits conflict in ways that greatly increase the complexity of decision making and the information needed to make decisions. New, more powerful system engineering techniques are required to deal with risk/risk decisions. 

I quote again from Griffiths Dealing with Risk The Planning, Management and Acceptability of Technological Risk ... 

Griffiths, Richard F., ed. Dealing with Risk. Manchester, UK Manchester University Press, 1981. 

Dealing with risks, as mentioned previously, aims to emphasize that the approach of hazards related to chemical activities for human health and the environment can be an important pedagogic strategy for the study... 

The above deals with risk assessment in respect of existing plant and premises. However, risk assessments at the design stage are becoming increasingly demanded. These require specialist knowledge of and experience in the operation of the particular plant and are often carried out by multi-discipline teams. 

There are many ways organizations and individuals deal with risk and risk concepts. This section will explore some variations in the application of risk concepts. 

Figure 34-2 also includes risk evaluation. In other models dealing with risk, the tasks under risk evaluation are part of risk management. Risk evaluation includes risk aversion and risk acceptance. Risk aversion is estimating how well one can reduce or avoid risks through various alternatives. Risk acceptance involves creating decision... 

Risk analysis and management is a field that deals with the anticipation and management of risk. Relevant to nearly every industry in existence, risk analysis and management provide a comprehensive set of tools, techniques, and methodologies that enable risk practitioners to deal with risk as appropriate. 

The procedure to deal with risk should then allow for analysis of how the risk is created and an assessment or evaluation of its extent. 

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