National Toxics Network, http://www.spirit.net.au/~biomap/ntn2.htm
NTN is a community based network with a common aim to
reduce the chemical load on the environment and to promote
environmentally responsible technologies and management systems.
NTN aims to be a true network reflecting a diversity of approach with a solidarity of purpose. NTN has interests in all aspects of toxic chemical pollution including regulatory and assessment issues. Over 300 groups and campaigners from across Australia as well as representatives from NZ and South Pacific, have already registered as network participants.
Members of the National Toxics
Network, have been involved in the issue of risk assessment and
risk communication for over a decade. Over this time the 250
groups and campaigners in our network have had to deal with the
issues of risk assessment, perception and communication in many
arenas ranging from contaminated land, species protection to the
siting of industrial facilities. I present this paper from an
unashamedly community perspective.
To focus this talk I would like to start with a quote from the US National Research Council 1989.
" To remain democratic, a society must find ways to put specialised knowledge into the service of public choice and keep it from becoming the basis of power for an elite."
In many cases, the community's perception of the risk assessment process is far from positive. It is often perceived as a powerful tool used by industry and government 'after the event' to dismiss real community concerns. There is often little trust in either the proponent or the process. There is little understanding of the actual risk analysis and what there is, is coloured by a basic resentment of yet another imposed risk, however small. There is also anger at the difficulties the community experiences in both accessing and understanding the full range of relevant information and this is then compounded by a total mistrust of the risk assessment's scientific 'experts'. For the community the traditional view of science as a rational, value free, objective and a socially neutral search for truth has been seriously undermined in recent years. The highly political debate surrounding the nuclear industry has left the bulk of the community confused and unwilling to readily accept the word of science.
So how do we move forward ? As community groups we are aware that risk assessment in some form is here to stay and we are also aware that without concerted action on all sides, the debate will not progress, the situation will remain adversarial and we will not reach the 'socially equitable negotiated agreement' that must be the basis for any effective risk management and mitigation.
To understand the breadth of community concerns, it is worthwhile examining some of the preconceptions and broad assumptions that underpin the risk assessment and communication process. This may suggest some ways forward.
The concept of the 'expert' in the
risk assessment process particularly EIA has inspired hostility
and mistrust. Despite statements about regulatory environmental
toxicology now being multidisciplinary, in our experience, the
expert in risk assessment process that the community meet, are
usually discipline specific, from outside the area which they are
studying and employed by government or business. For the
community this perception of the 'expert' is strongly coloured by
concerns of 'conflict of interest', put bluntly, the community
always asks, "Who pays the expert?"
Even when experts are drawn from the regulatory agencies, there is mistrust as community groups have watched regulatory 'experts' criss cross the professional ladder, from government to industry and back again. This is particularly so in the area of toxicology. The mistrust is further compounded by the utilisation of 'experts' from overseas at substantial cost and who can return there after their job is done.
At the same time 'lay knowledge' is usually dismissed, ignored and in the worst cases, ridiculed. Fortunately in more recent times, the growth in community monitoring has done much to return credibility to 'lay knowledge' and at least in the case of Koori groups, there has been some recognition by government and industry of the deep understanding of the lay community who know their 'backyard' intimately.
So often, I have seen valuable community generated data, surveys and advice ignored in an assessment process only to be validated years later. In the area of toxicology it has constantly been the general community who have alerted authorities to health and environmental impacts of chemical agents.
The terms 'expert' and 'lay' do little to assist the risk assessment debate and I would suggest that we accept a 'continuum' of knowledge and information in assessing risks, from the scientific to the experience based. This would provide not only access to a much wider range of relevant data but would go a long way in building a sense of community involvement and ownership in the process.
Those that have power / Those who do not .
The issue of 'lay' versus 'expert' is closely tied to the issue of power and control and these must also be addressed in a socio-economic framework.
Risks are often accepted as being inevitable due to financial constraints such as employment or the inability to buy a house in less polluted area or on a macro level, the inability to change world events,(eg., French nuclear testing.) Acceptance of risk in this framework is far from a success for risk communication, rather a response to disempowerment.
I have lost count of the number of times that government or industry reps frustrated at the repeated concerns of the community have responded with, "Well if you don't like it, why don't you move!" Although said in the heat of the moment, the underlying assumption is that people always have a choice. Despite the political rhetoric, it is well to remember many Australians do not have the economic freedom to choose where they live or work. Only recently at an air quality seminar held by EPA, a researcher responded to a question about air standards with the comment, that if people were silly enough to live in the CBD and then choose to work there, of course, their exposure to air toxics would be above acceptable limits. A true enough statement ? Or one that failed to understand that risk assessment must fully take into account social equity.
But power and control for the community are also linked to education, computer skills and the ability to understand the real 'nitty gritty' of risk analysis. The complaint so often heard is that the community is emotional and unable to grasp complex concepts particularly in relation to statistics yet are still unwilling to accept on face value the word of government or the RA proponent.
What has always surprised me is that at an international level, we accept that we must 'capacity build' and transfer technology to our developing neighbours, yet, we do not offer our own community the same privilege. If we wish an informed debate on risk analysis then we must put some effort into capacity building our own community. This is not 'pie in sky' stuff, the US provides community groups with access to software and expertise, why can't Australia.
Power also influences the notion of acceptability and while the preferred approach to risk communication is a 'dialogue reflecting a mix of interests, knowledge and values prevailing in the community' (Gay&Heath,'94), this is rare, and what usually occurs was well put by Fiscchoff's, when he said "each definition of risk makes a distinct political statement regarding what society should value" (Fischhoff, '85). It is often it is those in power and in influential position who define what is of value and subsequently what is then considered 'acceptable risk'.
Closely related to the issue of
power is the problem of community access to data and relevant
information. Community restrictions to information can be caused
by a variety of factors but the ones that prompt the most hostile
response are the claims by industry and government of 'Commercial
in Confidence' and the government policy of cost recovery in
regards to spatial data. This point was illustrated in the recent
community involvement in the Deferred Forest Assessment procedure
(an environmental risk assessment process for future logging
verses reserve status.) This process clearly highlighted the
inequitable access to the electronic data and basemaps that were
essential for community groups to participate equally in the risk
assessment process. Similarly, the continual claims for
commercial confidence in regards to chemical products, analytical
testing standards, factory storage and processes places the
community at a distinct disadvantage.
While we hear much about community as equal stakeholders in the RA process until they are provided with equal access to data and relevant information, this remains pure rhetoric. We also consider legislated 'community right to know' is a prerequisite for successful participation in the risk assessment process.
The issue of data access is complicated by the lack of quality data for the Australian context. If one accepts Scala's definition of "risk assessment in toxicology as a process whereby relevant biological, dose response and exposure data are combined to produce a qualitative or quantitative estimate of adverse outcomes ", then Australia is significantly 'behind the eight ball'. While we may have biological or hazard assessment data that is relevant, ambient levels, human exposure data or specific information on dose responses for our native wildlife is sadly lacking.
As was recently made pertinently clear in a the Regulatory Impact Assessment for the PCB Management Plan (National Advisory Body on Scheduled Waste 95), [RIA are a legislatively required cost/benefit assessments for modifications and new Acts.] , Australia still does not have the basic data on contaminants in the environment nor does it have exposure data for its human and wildlife population.
The discussion of data acquisition is often described in risk perception terms of involvement, uncertainty and desire to exert control, yet experience had shown us that despite the motivation for information acquisition, a key element in any successful community participation in risk assessment programs is the provision of easily understood and accessible information.
In 1993 after much lobbying, the NSW Regional Agriculture sponsored our research group to create the Dipsite Community Access Information System.
The issues relating to the assessment, management, remediation and liability of over 1600 contaminated cattle dip sites (DDT, Arsenic) in Northern NSW, required a well informed public that both understood the issues and felt some involvement in the management of the problem. This required access to information on site history, the toxicity of the contaminants and current chemicals involved, exposure pathways and the environments at risk. The information repository concept had already proven to be an essential component in USEPA conflict resolution over polluted sites.
In the case of the cattle dipsites, the provision of accurate up to date information not only promoted informed decision-making on behalf of the community, it facilitated community involvement and ownership of the contaminated sites affecting their area. Armed with accessible information, community groups such as Landcare became actively involved in managing the sites and the mitigation of environmental damage. For the affected residents, the information system provided the main source of much of the relevant information including the results of sampling of their backyard .
There is an inherent unfairness in
the risk assessment process that is often subjugated or explained
away by arguing general benefits to the community, "We all
need development." etc., but in reality it is often those
that take the risk and pay the cost that do not gain a direct
benefit. Nowhere is this more obvious than in the management of
contaminated land. While it may be an industry that polluted the
land in the process of making profits, it is often an unrelated
community who must live on the land, assess the risks and in some
case even pay the costs of cleanup. At the very least, financial
security is lost due to chemical contamination and the resident
is left to deal with stress and disempowerment.
While the much touted Polluter Pays Principle is just that, a principle with no legislative backing, risk assessment must address the issues of liability. It would be naive of us not to acknowledge the use of the risk assessment process in the political and commercial estimates of costs and benefits and the justification of actions or more often no action.
Nowhere was this more obvious than in the review of standards for DDT and Arsenic in soil. Literally residents living on contaminated sites went to bed one night with an investigation level for Arsenic of 30ppm in soil and woke up to a new level of 100ppm. Soon after the investigation level for DDT was raised from around 1ppm to 50ppm. The ramifications for buy-out, compensation and health concerns were immense yet there were no real attempts at community involvement in these risk assessment.
The well rehearsed argument that the community in general benefited from the industry's products often rings hollow, particularly in the case of chemical agents. The consideration of whether a society needed these particular products, never involved the community in the first place nor does it today.
In the assessment of the risk so often the only clearly recognised end point is death. The issue of quality of life and ongoing good health can be ignored. Yet there is no doubt that asthma and is on the rise and the incidence of some cancers have increased substantially.
NTN works with a action parent group in a NSW rural town. The children involved carry 'body load' of nonmethanic hydrocarbons such as benzene, toluene as well as chlorinated solvents and organochlorine compounds. The children appear to have ongoing health problems and are constantly in and out of hospital. Over the last 6 years the parents have called for air monitoring and health investigations. After years of lobbying the Regional Health Department carried out air monitoring for a particular pesticide. It did not monitor for the hydrocarbons of concern but it did detect chemicals used for termite control. The chosen pesticide which was looked for was not detected (and probably could not have been due to the sampling equipment) yet assurances were given that all was well. To this day no one has seriously investigated a connection between these children's illnesses and the contaminants they carry their small bodies.
For those suffering environmental health problems, risk assessment provides little comfort. I have never seen data on existing chemical body load factored into a risk analysis nor have I seen chemical sensitivities particularly in children built in to equation. In the case of environmental health, risk assessment is a blunt tool !
The role of trust in risk
perception and communication should never be underestimated. So
often I have heard the comment from regulators and industry,
"Why don't you trust us ?" Yet, NTN's database is full
of incidences highlighting misinformation and misrepresentation
of products, secrecy regarding processes, the withholding of data
and the list goes on. Most importantly, when the assessments of
the past are proven to be wrong, the only response is the excuse
of 'old science'.
This brings us to the jargon of 'old luggage versus new broom'. There is no doubt that the community brings with it our old luggage of mistrust and suspicion based on years of experience. The response by legislators and industry is but "we're a new broom, we'll run a transparent open process, full of meaningful consultation and information distribution". Yet community groups have heard this all before and so it will take a great deal of significant action to demonstrate that the game has really changed.
To change things around and build the good faith that is essential to the RA process, it will require a review of many of the old decisions made in secrecy and isolation that are still affecting people today. It will also require a cultural change in attitude where community knowledge is valued and incorporated into the decision making process. Most importantly, equal access to the data and relevant information will have to be assured for community stakeholders and industry and government will have to stop hiding behind commercial in confidence claims. The community will need resources to 'capacity build' those who wish to be equal players in the game. Further requirements will include an accessible decision audit as part of the publicly accessible information system to ensure community trust in the 'open transparent process' and there is a need for guaranteed provision for follow up monitoring and feed back to check the original risk assessment.
Certainly, the recent consumer response to the risk from mad cow disease in UK has illustrated the strength of community outrage and its refusal in this situation to accept any risk whatsoever. The issue of what defines "acceptable risk" is as topical today as it was a decade ago. I'm sure the figures for contracting Creutzfeldt-Jacob Disease would be well within the most stringent formal definition of 'acceptable risk' yet once aware of the possibility of hazard from consuming affected beef, the general population considered that the only 'acceptable' risk was no risk.
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