Obscure Risks

No News is Good News

Compared to chemicals that are intentionally added to food, the FDA has very little authority to regulate unintentional contaminants in food.  I therefore always thought that providing public information about the risk of contaminants in food to be a very important part of my job.  On paper at least, so did the agency since “risk characterization” was always part of my job description.  But even though I managed to publish analyses in academic journals that very few people read, anytime an analysis even started to become a public agency position, political interference arose.

Although there are many secondary reasons, the primary reason is that everyone wants to believe that the food they eat is perfectly safe.  But, I didn’t have to work at the FDA for very long at all to figure out that it isn’t, it never has been, and it never will be.  Sure, the agency does a pretty good job of protecting most people from big risks, in no way does the Center for Food Safety and Applied Nutrition protect everyone from every little real or imagined risk.  But that great truth would never pass through the lips of the press office.  About the only time the agency is willing to acknowledge a risk is when there is a regulatory policy that needs to be justified.  For example, a fish risk benefit analysis probably would have never made it to the agency web site if there weren’t accompanied by a fish consumption advisory.

As you might expect, suppression of bad food news is often strongly supported by the food. industry.  But, I think they are short-sighted.  Word gets out anyway; there is this thing called the internet these days.  When risks go uncharacterized, people often end up thinking the risks are bigger than they really are, which leads to the next reason.

Trivializing the Risk

It’s not as big as the food industry, but consumer advocacy keeps a lot of bodies busy these days.  There are big chunks of federal and local government involved, non-governmental organizations, and the media of course.   But, the backbone of consumer advocacy is in the academic sector.    Researchers will raise the presence of a chemical as an issue, conferences are sponsored, uncertainties are identified, research needs identified, and research is funded.  Then the issue goes away until the papers get published and grant money runs out, and then new conferences and uncertainties pop up.  This can go on for decades without anyone ever trying to figure out big the risk might really be or what might be done about it.  Since a chemical can become a career, the result of that is that many researchers have a financial interest in NOT reaching a decision.

Consumer advocates are also likely to be unappreciative of efforts to quantify risks when there are already public health programs to address them.  For example, fish consumption advisories have been issued by just about every state public health department without anyone trying to estimate what the risk is.   Risk characterizations that might either make ongoing efforts seem unjustified or give consumers information that would allow them to make their own decisions are therefore unwelcome.

Too Much Uncertainty

It isn’t really a reason, but a rationale often given for not quantifying a small risk is that there is too much uncertainty.  The effects are generally unmeasurable, so of course, there is uncertainty.  That doesn’t mean you can’t come up with a reasonable determination of how big the effects could be.  It also doesn’t mean that there can’t be some scientific disagreement about what the plausible range of effects could be or what the best estimate is.  However, it does mean that whatever the uncertainty is, it can be discussed and quantified, and notable uncertainties can be included in the characterization of the risk. 

Even though the too much uncertainty argument is often couched as a scientific argument, it’s really just a form of political censorship intended to protect the status quo – which can be virtually any career or financial interest that might be disrupted by new information.   A good constructive scientific criticism may be cause for a revision that will result in a better risk assessment; it won’t kill it all together.  Risks worth caring about are worth quantifying.  Certainty is a luxury rather than a necessity. 

Message Control

Good managers try to control what they can control.  Also, being in control is the sport that makes Washington tick.  As a result, most agencies don’t want to release information without carefully gauging how the public will receive it.  The FDA is no different.  If new data or a new issue arises they will study the problem until they feel they are ready to take control of the issue.  But, the problem with unintentional contaminants in food is that the FDA has very little control; certainly far less than what the public generally expects.  This is at least partly a self-inflicted problem because the agency and/or the department never wants to admit how little control it has.  So, when a public issue involving an unintentional contaminant arises, usually one of two things happen:

1. Delay. The problem is analyzed in perpetuity or until everyone forgets about it, whichever comes first.  Waiting for new research that probably won’t affect the risk estimate, if there is one, will usually buy a few years.  
2. Declare Victory.  The agency determines that nothing needs to be done, but still spins a message that sounds like something is being done.

I think the agency should give up on the control thing and just focus on providing trustworthy information, which is the sort of thing a Civil Service should be in a position to provide.  But, they won’t.  Oh well, I guess I’ll just do it without them.  Maybe if I set a good example they will see the advantage of not trying to maintain appearances.

Official Post Soundtrack

Barbieri R (2004).  Path Not Taken.  In: Things Buried, Track 9.

Post Note

Thesis Post #40. A second introductory essay for the Personal Risk Assessment thread. I eventually plan of following with some actual risk assessments, with the first one being a reworked version of the fish risk benefit analysis.