Major Flaws of Conventional Risk Assessment

• Risk assessment assumed “assimilative capacity” that is, that humans and the environment can absorb a certain amount of pollution and render it harmless. Eliminating risk altogether is not the goal of risk assessment — it is used to manage and reduce risks, not to prevent harm.
• Risk assessment focuses on quantifying and analyzing problems, rather than solving them. It asks, “how much pollution is safe or acceptable; which problems are we wiling to live with; how should limited resources be directed?” It does not ask, “how do we prevent harmful exposures; move toward safer and cleaner alternatives; involve society in identifying, ranking, and implementing solutions?”
• Risk assessments use different models with high uncertainty. Current risk assessment is based on many different assumptions about exposure, dose-response and the extrapolation of results from animals to humans. In one exercise, 11 European governments established teams of scientists and engineers to work on a problem concerning accidental releases of ammonia. The result of the exercise was 11 different risk estimates ranging from 1 in 400 to 1 in 10 million. The organizers concluded that “at any step of a risk analysis, many assumptions are introduced by the analysts and it must be recognized that the numerical results are strongly dependent on these assumptions.” (Contini, et al. 1991, Benchmark Exercise on Major Hazard Analysis. EUR 13386 EN Commission of the European Communities, Luxembourg)
• Risk assessment allows dangerous activities to continue under the guise of “acceptable risk.” It allows the continuation of activities that lead to greater pollution and degradation of health under the premise that it is either safe or acceptable to those who are exposed. It prevents action.
• Risk assessment is fundamentally undemocratic. The risk assessment process is most often confined to agency and industry scientists, consultants and sometimes a high-tech environmental group. It traditionally does not include public perceptions, priorities, or needs, and does not use widespread public participation.
• Risk assessment puts responsibility in the wrong place. It assumes that society as a whole must deal with environmental harm, because “that is the price of progress.” It diverts attention from those responsible for harm and those who created it. It focuses government resources on studying the problems rather than identifying safer alternatives to potentially dangerous activities.
• Risk assessment often poses a choice between economic development and environmental protection. Governments and industry often tie ‘scientific’ process of risk assessment to cost-benefit analysis but fail to question who assumes the cost and who reaps the benefits. The economic benefits of cleaner production have been clearly demonstrated but often not acknowledged. Also, the cost of underregulating will typically be greater than overregulating, when considering the subsequent cleanup and health costs.