The Quantitative Risk Assessment, hereinafter called "ECR", aims to determine the number of people who may become ill or die as a consequence of a particular risk.
These should be the best times for a Risk Management Consulting professional. I am a professional adviser specialized in risk management, a profession that is rapidly gaining importance worldwide, particularly in the most developed. One of the reasons that underpin the importance of the growing demand for risk professionals has to do, to a large extent, with the nature of the health risks and the ever-changing environment that we face today.
Before, we did not need to carry out prior risk assessments, with a consequent action plan to remedy adverse situations such as those specified, when rivers were engulfed in flames. The new generation of environmental threats, generally classified as "not very serious", are much more difficult to measure and eliminate. When toxic chemicals are dispersed in an open field for several decades and some of these chemicals appear to permeate the earth until they reach underground sources of drinking water, the necessary questions arise.
First, should the contaminated field be cleaned? And, secondly, and if so, how far should the actions of environmental recovery of the affected area go? When a factory air contains potential carcinogens, would employers find themselves in a position to drastically restructure their companies and at a higher cost?
The Quantitative Risk Assessment attempts to provide information to legislators, especially Americans - this is not exclusive to any nation, so that they respond, rationally, to the questions raised above.
The Quantitative Risk Assessment aims to determine the number of people who may become ill or die as a consequence of a particular risk. This methodology also aims to determine how many savings, in terms of human and economic resources, could be produced with its implementation.
ECR is a young discipline, dating back about 17 years.
At the beginning, risk advisers received countless criticisms from the left of the political spectrum. Over time, the notion of the value of saving human lives could be, to some extent, quantified and compared to the costs of official regulation, which was anathema to many interested in the public interest. In more recent years, this attitude has changed and it has been thought that the establishment of these relatively new values are not immoral (even if establishing a very low cost, it could be).
The most incredible and recent event has been the importance that the right has attached to the Quantitative Risk Estimation ("ECR") in the United States and, especially, the so-called "Regulatory Reform", whose central provisions were contemplated in the "Republican Contract with America". Because of the legislation passed by the House of Representatives, the Senate will have to attach a great and unprecedented importance to risk assessment. In fact, each new regulation related to health or environment, in that nation, must have the «ECR» certification. I am in favor of creating a greater demand for risk advisers, as long as the necessary and corresponding budgetary forecasts are made in whatever country of the world.
Why, then, do I think this is the worst time to be a risk assessor in the United States as an example? The answer is that the Congress of that country is trying to reduce the budgets of government agencies that practice "ECR", such as the Occupational Safety and Health Act, known in English with the name and acronym <> ("OSHA"), respectively, and the Environmental Protection Agency ("EPA"). However, even more relevant is the great rejection that, in their own way, the Congress, the Academies and the media have dispensed with the «ECR». Some reforms are based on the myth that the current risk assessment uses methods that exaggerate the risks, at a high cost to society. In my opinion,risk assessment is in danger of being omitted from granting a scientific discipline certification. At times, risk management advisers feel like chemists who see their professional field as finally going to be formally recognized and then discovering, in practice, that the government was actually preparing to impose alchemy as a state science.
The idea that risk assessment is overly conservative first appeared, a decade ago, in some scholarly articles, with titles such as: "The Dangers of Prudence: How Conservative Estimates Distort Legal Regulations?". Many public figures have adopted this position. Stephen Breyer, now a Justice of the United States Supreme Court, in his book "Breaking the Vicious Circle", published in 1993, argues that there is an irrational public desire to fear the worst and that risk estimators add to that fear. He concludes his work by noting that many of the big risks, according to government estimates, are actually "laughably small." In another passage from his work, as an example, Breyer tells the story of a New Hampshire company that has been ordained,by direct instructions from the "EPA" to disburse $ 9 million to clean a "waste site", so that children can "eat, there, land for 245 days a year", even though the place referred to is, by practical definition, a swamp.
Many in the US Congress believe anecdotes like these are correct and illustrative. In support of the law reform that Mr. Breyer, Senator Bob Dole, Senator J. Bennett Johnston (Democrat for Louisiana) argue that "the current federal agencies are not using" good science "and that their regulations are disastrous ». The Dole-Jonhston Act, like the one previously passed by Congress, would resolve the issues raised, by establishing a framework for risk advisors on how to estimate such risks. The "conservative" procedures referred to above, which we use today, will be replaced by those that help to achieve the "best estimate". Consequently,This implies that regulators will only focus on the risks to which an "average person" is exposed. According to the modification to the law already explained, in the same way, different theories should be calibrated regarding the evaluation of risks, trying to average the results as a whole (however, the Law is mandated to choose the most "plausible" theory, regardless of whether the results obtained are, in reality, below average).
The generation of the "best" or the most "plausible" risk estimate appears, in principle, to be the result of common sense that we should all aim to follow.
Is this really the purpose? To make up your mind, you need to answer two questions that critics of the current "ECR" would ask themselves. First, what is the evidence to assess, other than Judge Breyer's anecdote, that today's risk estimates are biased toward an overly conservative methodology? Secondly, if the risk estimates are really biased towards a conservative methodology, is the difficult solution to the serious social problem that is required compatible with the truly "best" estimate?
Let us address the first question. I urge you to think about what it means to protect the "average person" from the "average risk." As far as risks are concerned, the vast majority of individuals are not average, their degree of exposure to risks varying markedly, as well as their susceptibility to contamination (such as body weight could vary). Would you say that a ladder for a 63 kilogram person is the "best", while another could support a 90 kilogram person would be considered as a futile and biased example towards an attitude that "it is better to be safe than to be regretting the imponderados ?. The answer to this is probably "NO". However,When OSHA calculates the risk of a worker who works in the same industry and breathes the same pollutants for a span of 40 years, perhaps twice the national average for the United States, then he is accused of applying "bad science." Therefore, the "EPA", when evaluating the risk of residual pesticides in apple juices, under the assumption that children are more vulnerable than adults and consider that the latter drink up to three glasses of juice a day (even when the average population drinks less than one glass), we design regulations to protect the average person, constituting an alleged justification for the risk assessor, we could fail to protect (health), adequately, numerous segments of the population. Would this practice really bevery committed to "good science"?
Then there is the question of how much it would cost to determine the value of an "average risk." All risk estimates involve uncertainty.
For example, when you try to estimate, from laboratory and epidemiological studies, how potent a carcinogen can be, and starting from the premise that you are honest with yourself, you will get a whole range of answers. Choosing the average value from a range of results is not more scientific than the instrumentation of other alternatives. All choices are value judgments insofar as they impact the balance between health and economic costs, underestimating the risk and costs of overestimation. The process of "unbiased average picking," as it sounds, merely implies that those costs are exactly the same, which is really and quite a big bias.
Let me explain with another analogy. Suppose you are told that the average amount of time you need to get to the airport from your home is 20 minutes, but in reality this journey could take 5 to 80 minutes. If you prefer to arrive 4 minutes late to your plane, instead of arriving at the airport 5 minutes early, then you should be guided by the so-called "estimated average". But for those people who consider losing the plane (or allowing pollution to cause unnecessary death) as more adverse than waiting for a few additional minutes (or wasting some money on extremely strict pollution control), an even more cautious estimate is required. Risk advisers traditionally focus on the "reasonably worst case scenario."They seek to give themselves more than an opportunity to overestimate risk in order to be reasonably sure that risks will not be underestimated.
If, instead of averaging the various risk estimates, we simply chose to consider the "plausible" estimates together, we would be in worse shape. How do we decide which of the two methods is the most "plausible"? The answer would be, perhaps, through the knowledge of the vote of several experts in the area. Suppose, if I may share with you another analogy, that a hurricane is approaching the Florida coast, thus having on the balance two theories about the possibilities and probabilities of the behavior of such a wind movement. Forty percent of recognized experts believe that a storm will hit the coast and end in the city of Miami, while the other sixty percent believe that it would fade into the ocean. Consequently, we should decide on the last theory,since it is more "plausible", and, therefore, omit to alert the city of Miami.
In this light, risk assessment reflects more than just the "average risk" for "the average person" and that they are both conservative and plausible results, and the requisite common sense is beginning to be sought. In fact, they are the benefits of common sense that our society has applied when confronted with other problems, achieving either success or a great approximation to it. We deal with uncertain threats based on prudence. This is one of the reasons why there was no automatic clamor of "being right" as to the exact probability of Soviet aggression during the Cold War. Instead, it acted based on the reasonable possibility that the threat would be serious enough to warrant a truly onerous response. We recognize that individuals, every day,They vary from expectations of the average when we build doors big enough for increasingly tall people and stairs for increasingly heavy people (however, this is not the case with polarizing to the other extreme and, for example, building doors and ladders for people of 2.5 meters and 180 kilograms, respectively).
Much importance has been given to the idea that the "best estimate" will guide us on the natural path of "objective" or common sense regulations. However, the great irony of the current debate is the surprising lack of reliable evidence on which today's risk assessments skew towards a highly conservative trend. It has become a daily chore to underestimate animal experiments by specialized risk assessors when evaluating presumptive carcinogens. Critics of risk advisers say: "Increase the doses of chemicals in laboratory mice" and, of course, we will see how the occurrence of cancer is overestimated in people whose exposure to such chemicals is minimal.
But what is the factual reality? In 1988, a team of scientists in Louisiana attempted to investigate, by systematically comparing the results in the animals studied with the best available analyzes of cancer epidemiology, concentrating on exposure to carcinogens in the workplace. The researchers considered all 23 known carcinogens, including benzene, vinyl hydrochloride, and asbestos, analysis for which a quantitative matrix of comparisons was used. These researchers concluded that, on average, the number of human deaths predicted based on animal studies only slightly exceeded the actual level of death. Additionally, in the order of 23 studies carried out on animals they underestimated the harmful damages, in general,for the people.
Recently, a study of 24 cases has dramatically illustrated the absurdity of ruling out results in animal testing. In 1990, OSHA was prepared to regulate a toxic gas to a 1.3 degree, for the production of synthetic rubbers. Animal studies have predicted that humans exposed to this gas have an 8 in 1,000 chance of developing cancer from this gas (that derived from exposure to the toxic gas in question). OSHA wanted to reduce the reference toxic gas limit allowed from 1,000 to 2 units of measure. Then, in the early 1990s, a series of academic and editorial articles appeared denouncing this government initiative as excessive, on the grounds that the results obtained with laboratory mice were irrelevant to humans.To safeguard its credibility, the plastics industry continued epidemiological studies with its own workers, exposed to the aforementioned toxic gas. A few months ago, the preliminary results of the studies, on behalf of the industrialists, seem to suggest that their workforce had developed a level of cancer that was consistent with the results and predictions obtained from the animal studies. Now, the plastics industry, the respective unions and OSHA are urgently demanding that a regulation be decreed immediately, allowing the level of the explained toxic gas to be reduced to 50% less than the amount suggested in the best scenario., representing half of what was originally proposed. If you had considered, six years ago,animal studies, some cases of cancer would have been prevented.
To be safe in their practices, most risk assessors make assumptions that tend to exaggerate the risks. For example, these people tend to assume that exposed units (people, animals, etc.) are confronted with the risk of carcinogens. 24 hours a day instead of considering 8 hours a day. The pending legislation would allow the courts to challenge any regulation that is based on the assumptions explained here, on the basis that these assumptions introduce over-estimates of risk exposure. However, dozens of assumptions are associated with risk assessment, and critics tend to ignore those assumptions that are not adverse to us, but are instead favorable. For example, toxicologists routinely slaughter laboratory mice age 24 months.This age in the tested animals is not compatible (or equivalent) with a human being of about 70 years of age. British statistician Richard Peto has shown that, if they expected animals to die of natural causes, keeping track of all tumors produced by test substances, their estimates of carcinogen generation could grow exponentially.
After all, no one has yet succeeded in detecting systematic bias in current risk assessment procedures, except for the wish, not always satisfied, to protect people who are not within the edges of the averages. It is worth saying that these people represent the vast majority of cases, as I explained previously. Some of the most striking stories about absurdly exaggerated risks are undoubtedly true. Risk assessment is difficult, and even difficult, for mature and well-intentioned professionals, who, from time to time, may also be surprised by the results obtained. In any case, the vast majority of anecdotes do not yield, in practice, elements of information that serve to arbitrate precautionary formulas. As an illustration,Consider the case of "Alar," the growth regulator used by apple growers, who withdrew from the market in 1989 when the Environmental Protection Agency ("EPA") banned them. This case, in particular, has become a very notable action as a sample of what the above-jealous regulation represents. In 1991, an animal study by "Alar" found that Alar caused as many tumors as "EPA" had assumed and at even lower doses.In 1991, an animal study by "Alar" found that Alar caused as many tumors as "EPA" had assumed and at even lower doses.In 1991, an animal study by "Alar" found that Alar caused as many tumors as "EPA" had assumed and at even lower doses.
Likewise, one might consider the fable of "Children Who Don't Eat Dirt in the Playground" in New Hampshire. In fact, the site of toxic waste was not properly in the swamp, it was, rather, in an open, suburban land. However, the land was zoned to be urbanized at the time. Nor did the "EPA" assume, as Mr. Breyer implied, that "the children carried land into their mouths 245 days a year" when it then ended up ordering special environmental rescue work. It was assumed that the amounts of pollutants would inevitably find a way to permeate children with toxic substances contained in the soil with which they would be playing.Toxicity studies suggest that the amounts of harmful substances detected would be enough to put children in question at an unacceptable level of risk. Was the green recovery work worth $ 9 million worth considering how difficult it is to raise funds today for countless social problems? I'm not sure, but the responsibility, if any, rests with the responsiveness with which the risk assessment provides us, and not the generic response that science per se can provide us.if any exist, it rests on the responsiveness with which the risk assessment provides us, and not the generic response that science per se can provide us.if any exist, it rests on the responsiveness with which the risk assessment provides us, and not the generic response that science per se can provide us.
Obviously, if the cleanup had only cost $ 9,000, Judge Breyer would not, presumably, have acted in the way that he did if a sum, rather, of $ 9 billion had been required and the "EPA" would have been interested in other environmental risks. In order to make decisions committed to the respective cost-effectiveness, obviously you need to know the costs and benefits of the action you are contemplating taking. The United States Congress is now considering the prescription of a dozen regulations pertaining to risk assessment, without mentioning, in any way, the problems of the cost analysis itself. To be sure, calculating the cost of economics from health or environmental regulations is as difficult as it is full of uncertainties in assessing one's risks.On the other hand, the evidence that the costs, de facto, are routinely exaggerated much more forcefully than the evidence on the validity of the risks themselves.
Measuring the direct cost a company has to comply with regulation is the easy part of cost evaluation, an action that is often wrong by risk advisers. Risk advisers, in general, are obliged to estimate the technological price even before the requirement to implement the corresponding technologies occurs. In other words, the technology providers have found some facilities to reduce their prices before the users have learned how to use it efficiently or before each of the groups has developed entirely new ways to achieve technological compliance. In certain cases, under a worse scenario, regulatory agencies must frequentlypartially rely on engineers from self-regulated companies for cost estimates. Those engineers (employees) are obviously opposed to underestimating costs for their companies. Anecdotally, regulatory agencies have the same aversion: if costs are overestimated, they will be less vulnerable in court to act on the grounds of incorrectly declaring an economically feasible regulation.they will be less vulnerable in court to act on the grounds of having incorrectly declared an economically feasible regulation.they will be less vulnerable in court to act on the grounds of having incorrectly declared an economically feasible regulation.
For all these reasons, direct costs tend to be overestimated when they are first implemented. As an example, one of the most onerous "EPA" programs involves controlling nitrogen oxide emissions from factories and power plants. Emission control equipment manufacturers recently reported that it now costs between a fifth and a half the amount that regulators had initially estimated. In a very recent comprehensive study, the now-defunct United States 'Office of Technology Assessment' examined the costs of seven core regulatory programs under OSHA mandate. In no event have companies spent more than OSHA predicted amounts, and in five out of seven cases companies have spent substantially less.
Furthermore, the cost of regulatory compliance is only the beginning of the story. When OSHA regulated vinyl hydrochloride, a carcinogen used in the production of plastic, the controls were very expensive, but they paid for themselves by increasing the amount of valuable products recovered. When cotton dust was regulated, it controlled for an economy of hundreds of thousands of workers with lung diseases, while helping to modernize and revitalize the increasingly declining textile industry in the United States. The case of «Alar» is another example of a poor presentation of an underestimated estimate. While many apple producers, specialized in two varieties, depend to the maximum on «Alar», «Red Delicious» and «McIntosh»,he suffered economic inclement for a number of years before his retirement. Consequently, farmers of other fruit varieties experienced an exponential increase in their sales. Generally speaking, consumer demand for apples, as well as the profitability of the respective industry, has practically doubled since the carcinogenic chemical was discontinued. The losses incurred by farmers did not disappear, as this is not the whole story. Some sectors of a regulated industry may, in reality, benefit from regulations, as is the case with other industries such as pollution control equipment, which is not usually focused on economic methods for cost analysis.Farmers of other fruit varieties experienced an exponential increase in their sales. Generally speaking, consumer demand for apples, as well as the profitability of the respective industry, has practically doubled since the carcinogenic chemical was discontinued. The losses incurred by farmers did not disappear, as this is not the whole story. Some sectors of a regulated industry may, in reality, benefit from regulations, as is the case with other industries such as pollution control equipment, which is not usually focused on economic methods for cost analysis.Farmers of other fruit varieties experienced an exponential increase in their sales. Generally speaking, consumer demand for apples, as well as the profitability of the respective industry, has practically doubled since the carcinogenic chemical was discontinued. The losses incurred by farmers did not disappear, as this is not the whole story. Some sectors of a regulated industry may, in reality, benefit from regulations, as is the case with other industries such as pollution control equipment, which is not usually focused on economic methods for cost analysis.as well as the profitability of the respective industry, has practically doubled since the carcinogenic chemical was discontinued. The losses incurred by farmers did not disappear, as this is not the whole story. Some sectors of a regulated industry may, in reality, benefit from regulations, as is the case with other industries such as pollution control equipment, which is not usually focused on economic methods for cost analysis.as well as the profitability of the respective industry, has practically doubled since the carcinogenic chemical was discontinued. The losses incurred by farmers did not disappear, as this is not the whole story. Some sectors of a regulated industry may, in reality, benefit from regulations, as is the case with other industries such as pollution control equipment, which is not usually focused on economic methods for cost analysis.as is the case in other industries such as pollution control equipment, which is not usually focused on economic methods for cost analysis.as is the case in other industries such as pollution control equipment, which is not usually focused on economic methods for cost analysis.
Economists have more than two centuries using these methods, but these methods are still not very practical. Why, then, are many economists so impatient and foolish in their views of risk advisers? The most recent study in risk assessment, an effort by two experts over three years, selected by the United States National Academy of Sciences, concluded that "risk assessment methods are fundamentally correct notwithstanding the frequent criticism presented »If the members of Congress who are now trying to rewrite those methods by political orders were aware of the aforementioned study, even those members would not be impressed.
The practice of risk assessment, as I mentioned at the beginning, is so relatively young that it could still be severely and unjustifiably disdained by a group of qualified professionals with flushed (over-specialized) vision.
To perform risk assessments, one needs to have a basic understanding of toxicology, environmental chemistry, statistics, physiology, and other fields of specialization. Specialists abound in most of each of the specialties, but they have serious difficulties communicating with their counterparts from other specialties, but these specialists also have difficulty communicating with specialists in their own area, and, in the meantime, the much-needed generalists are too scarce. There is one point on which I agree with Judge Breyer, for example, he suggests the creation of a highly professional and cross functional group that specializes in risks and rotates through the different regulatory offices, the judiciary, the congress offices,to help improve the field of Risk Assessment and that this improvement is compatible with the growing expectations of the population.
In the meantime, we cannot require greater risk or quantity of risk assessment than it can offer us, particularly in the face of the "dynamics of change", its acceleration and the apparently sudden arrival of the Future into our Present. Above all, we should not aim to promote so-called "good science" when we are really pushing political ideology, reaching a converging point that less government regulation, especially where health and the environment are involved, is always a step. It is not that there is any pernicious game with value judgments. In reality, risk assessment can dispense with value judgments.It is just that these value judgments must be explicit and not allowed to act as the undercover of objectivity. Here I offer you my values, the first that drove me towards this professional activity from the beginning. I believe that risk assessment, as it is practiced today and continually improved, can help us protect our health and the environment more economically and efficiently, preventing us from unnecessary bodily injury, illness and death. I think that any society that cares about how important it is to save a life or protect its ecosystem. Genuine and "best" risk assessment is a practice that encourages decision-makers to be honest about uncertainties, taking intelligent and humane measures to reverse uncertainties.Here I offer you my values, the first that drove me towards this professional activity from the beginning. I believe that risk assessment, as it is practiced today and continually improved, can help us protect our health and the environment more economically and efficiently, preventing us from unnecessary bodily injury, illness and death. In my opinion, any society that cares about how important it is to save a life or protect its ecosystem. Genuine and "best" risk assessment is a practice that encourages decision-makers to be honest about uncertainties, taking intelligent and humane measures to reverse uncertainties.Here I offer you my values, the first that drove me towards this professional activity from the beginning. I believe that risk assessment, as it is practiced today and continually improved, can help us protect our health and the environment more economically and efficiently, preventing us from unnecessary bodily injury, illness and death. In my opinion, any society that cares about how important it is to save a life or protect its ecosystem. Genuine and "best" risk assessment is a practice that encourages decision-makers to be honest about uncertainties, taking intelligent and humane measures to reverse uncertainties.I believe that risk assessment, as it is practiced today and continually improved, can help us protect our health and the environment more economically and efficiently, preventing us from unnecessary bodily injury, illness and death. In my opinion, any society that cares about how important it is to save a life or protect its ecosystem. Genuine and "best" risk assessment is a practice that encourages decision-makers to be honest about uncertainties, taking intelligent and humane measures to reverse uncertainties.I believe that risk assessment, as it is practiced today and continually improved, can help us protect our health and the environment more economically and efficiently, preventing us from unnecessary bodily injury, illness and death. In my opinion, any society that cares about how important it is to save a life or protect its ecosystem. Genuine and "best" risk assessment is a practice that encourages decision-makers to be honest about uncertainties, taking intelligent and humane measures to reverse uncertainties.I think that any society that cares about how important it is to save a life or protect its ecosystem. Genuine and "best" risk assessment is a practice that encourages decision-makers to be honest about uncertainties, taking intelligent and humane measures to reverse uncertainties.In my opinion, any society that cares about how important it is to save a life or protect its ecosystem. Genuine and "best" risk assessment is a practice that encourages decision-makers to be honest about uncertainties, taking intelligent and humane measures to reverse uncertainties.
