COMPARATIVE RISK ASSESSMENT
I believe that it is important for this Committee to continue to examine tools for improving the ways in which we protect public health and the environment.
We need to always look for new approaches to addressing lingering or emerging environmental problems. We must determine which of these tools will give us the results, and the efficiencies, that we need.
And at the same time, we must set environmental priorities more effectively than we have in the past so that our efforts, and the money that is available, will address the most pressing problems.
I believe that risk-based tools -- such as comparative risk assessment -- have much to offer in this regard. Because of this, I have long been a strong supporter of the use of risk assessment as an environmental policy tool.
For example, I worked hard with Senator John Chafee and other members of this Committee to find an appropriate role for risk assessment when we amended the Safe Drinking Water Act in 1996. I am proud of what we came up with. I think we significantly improved that law.
At the same time, however, I have also long believed that we need proceed carefully and thoughtfully as we consider using risk-based tools. We need to clearly understand what each tool can do. And what each can't. Otherwise, we may end up expecting too much or too little of them.
For example, while I'm a supporter of risk assessment, I often think that its most ardent proponents oversell it. They simply gloss over inherent limitations to risk assessment, such as the gaps in data or scientific understanding, the absence of important analytical methods, and the sensitivity of this tool to underlying assumptions.
We need to be honest about risk assessment. We take its strengths -- and weaknesses -- fully into account in each and every application of risk assessment.
Further, it is important to remember that any tool we may decide to use to assist in decision making is just that, a tool. There are no "silver bullets" for decision making.
One of the reasons for this is that, despite when we may hear sometimes, the "science" we must depend on is, and can never be, complete. That's simply the nature of science.
I recall a speech made by Senator Smith, one he made when he first became this Committee's chairman, in which he said that we can't deny a problem just because the science is uncertain. I couldn't agree more. If we waited for scientific certainty, we'd end up deferring action on every single environmental problem we face.
Furthermore, it is critical to recognize that values such as fairness, equity and other subjective judgments are essential components of any environmental decision.
A risk assessment may legitimately find that, for most Americans, hazardous waste sites pose little risk. But it is equally legitimate, from the perspective of fairness or equity, to ask whether this means we should decide not to protect the health of the minority of Americans who happen to live near these sites.
The bottom line is that, when used carefully and thoughtfully, tools such as risk assessment can be extremely helpful in informing environmental policy decisions. But they cannot by themselves make these decisions.
RESIDUAL RISK
Before I end, I would like to say a few words about the second part of today's hearing, residual risk. I look forward to hearing from our last panel about the status of the residual risk program.
As everyone here knows, we're gradually beginning stage two of the ambitious control program for toxic air pollutants that we started in 1990. The MACT standards are almost all done now and EPA has begun to look at reducing the risks to public or environmental health that remain after MACT has been applied.
Some people have questioned whether EPA has the ability or the resources to regulate to get rid of "residual risk." They suggest that EPA doesn't have enough data or the right data or the right models. Some of those criticisms may be partly on the mark, but that has a lot more to do with funding than "science."
Residual risk was a carefully considered provision of the 1990 Amendments and it was not adopted lightly. We understood that there would be significant uncertainties associated with estimating risk.
That's why we required a report to Congress first, with any necessary regulation to follow. And, that's why EPA has to consider costs, energy, safety and other relevant factors, before issuing regulations to reduce residual risk
I look forward to making this program work and further reducing toxic air pollution.
Again I would like to thank Senator Smith for holding this hearing. I hope it provides this Committee with an opportunity to learn much more about EPA's residual risk analysis, as well as comparative risk assessment and what it has to contribute to improving environmental decision making.