ABSTRACT
Comparative risk analysis (CRA) is a term used to describe a rapidly growing number of projects performed around the United States by state and local groups as a promised new cure for “irrational” environmental management. CRA is supposed to combine the “science of risk analysis” with “community values” (Stone 1994). However, close examination of several CRAs performed recently by the states and local groups, indicates that neither scientific risk analysis or community values are properly incorporated. The name “comparative risk analysis” is a misnomer and a distortion of the term risk analysis. Moreover, attempting to use such CRAs for setting environmental priorities may do more harm than good, because the public is led to believe that decisions are based on “objective risk science,” while, in fact, it is only the opinions of the groups involved in conducting CRA (often industry and government dominated). CRAs seem often to be used as a means of speeding up the process to meet unreasonable deadlines and satisfy officials eager to embrace CRA as a cost-cutting measure in environmental management (mostly for polluters).
Although performing CRA adequately may be difficult, requiring integration of many different disciplines, it can be done so long as proper precautions are taken, the limitations of the analyses are clearly spelled out, and the results are used with caution. The U.S. Environmental Protection Agency’s (U.S. EPA) goal to manage environmental issues, based in part on the magnitude of risks to human health and ecosystems, can be achieved only if good science is practiced and proper procedures are followed in performing risk analyses (U.S. EPA 1987, 1990, 1993). While procedures for simpler types of risk analyses (such as estimating health effects of a 274particular chemical or process) have been developed, methods that would enable comparing various types of problems and multiple stakeholders values attached to those problems and/or their solutions still need to be developed. A good starting point may be a multiattribute utility theory, which provides a mathematical framework for analyzing choices involving multiple competing outcomes (Kadvany 1995). However, any model one may conceive for such a purpose must be validated if it is to be useful. Also, one should not forget that some complex questions are unanswerable and that only time will show the validity of our predictions . True CRA could become an ongoing process in which an interdisciplinary and long-term approach could be applied in evaluating and solving environmental problems using the advances in the fields of risk analysis and decision analysis. Ironically, this type of environmental problems analysis and management is very close to the medicinal circle approach of some native American tribes where the knowledgeable elders of the tribe (interdisciplinary group of experts) would discuss the impacts of important decisions on seventh generation (long-term approach to environmental management).
