Thursday, May 7, 2015

Three Is a Crowd

Risk Analysis

The Society for Risk Analysis (SRA) was established in 1980, three years before the NRC (1983) Redbook.   While the founding constitution and bylaws were modified from those of the Society of Toxicology, the vision statement reads as follows:

The Society for Risk Analysis is a multidisciplinary, interdisciplinary, scholarly, international society that provides an open forum for all those who are interested in risk analysis. Risk analysis is broadly defined to include risk assessment, risk characterization, risk communication, risk management, and policy relating to risk, in the context of risks of concern to individuals, to public- and private-sector organizations, and to society at a local, regional, national, or global level.

There are two aspects of SRA that stand out.  First, the primary goal is synthesis.  Instead of creating a new independent field of study, it draws from other fields.  In fact, risk analysis draws from just about every field of study known to man, including biology, chemistry, economics, epidemiology, law, mathematics, philosophy, physics, psychology, public policy, and statistics.  As might be expected, the actual academic disciplines involved vary with the actual issue, which leads to the other distinction: Risk Analysis is an applied field that deals with issues that are of current interest.

The Third Wheel and the Big Wheel

In the Redbook Risk Assessment Paradigm, all the various disciplines boil down to two main areas of discourse: Risk Assessment and Risk Management.  The scientific and mathematical disciplinesthat are concerned with what we know all figure into risk assessment in some way.   On the other hand, any field that is concerned with what ought to be done pertain to risk management.  That certainly includes the study of public policy.   But interdisciplinary arguments can arise over what’s what.  For example, I think of economics or any other exercise that assigns values to outcomes as being largely associated with risk management, but many economists will argue that they are pursuing the objective truth of the value of currency.   Some disciplines, like risk analysis, are naturally concerned with the interaction between risk assessment and risk management.  Philosophy is a prime example; while metaphysics and epistemology are concerned with what we know, ethics is part of the “ought” dialog. 

But the generally accepted view of Risk Analysis for food safety these days is that there is a third main component comprised of Risk Communication (e.g. USDA and USFDA, and FAO):


Since the whole point of SRA is to facilitate communication between different disciplines, identifying Communication as a separate endeavor is quite odd.   Interdisciplinary or interagency communication is not easy.  There is indeed an abundance of technical and bureaucratic jargon to wade through.  The employment of different concepts of probability (Kaplan, 1997) can quickly turn a discussion about risk into the Tower of Babel.   A very talented multi linguist who is familiar with all of the subjects could surely could facilitate public policy debates involving highly technical subjects:


But, that’s not it.  More often than not, what Risk Communication is really about is communicating with the public (WHO, 2005).  That could mean a dialog where the public is educated about the technical issues and included in the public policy discussion.  But, that’s usually not quite it either.  As an academic field risk communication is a branch of psychology that studies consumer response to various messages about risk (Slovic, 2006).  As an applied field, risk communication is a form of political propaganda.

Politics

Make no mistake, risk analysis at a regulatory agency is political.  In fact, the main function of risk management is political resolution of the value judgements involved in making a decision.  As a separate process, risk communication is a process for promoting the decision after it has been made.  But, at least in a democracy, good risk management can’t work that way.  Being aware of how the public will react needs to be an integral part of the decision process, rather than something that is tacked on later.  So, at best, Risk Communication is an integral part of Risk Management – which means is doesn’t need to be a third category all by itself.  So, why is it?  Here are two potential bad reasons:
  • The Public is Being Sold a Bad Decision.  Nobody needs trust more than someone who doesn’t deserve it.  This may involve hiding a risk, selling a risk that really isn’t there (e.g. a weapon of mass destruction) or hiding ineffective risk management.  Or, it may involve hiding the fact that no one considered the interest of the public at all.  The latter possibility is especially likely when the agency decision process is formulaic.
  • The Decision is Still Being Made.  Here, the risk communication exercise really is the risk management process.  Except for the pretense of risk management that really hasn’t happened yet, this reason isn’t so bad.  Like reason #1, this is symptomatic of an irrational or inefficient bureaucracy, but at least there is some semblance of responsibility for a decision.  Late is indeed better than never.

Risk Paralysis

Left unchecked, an exclusive emphasis on politically effective messaging can result in the evil twins of risk analysis:

  • Risk Manglement.  Answer no questions; tell no lies.
  • Risk Caressment/Harassment.  Persuade the analysis to support the message, or at least provide a technical distraction.  If a carrot doesn’t work, use a stick or hire another consultant.

The cure for that is dialogue.  One of the problems with the Redbook (NRC, 1983) formulation of the risk assessment paradigm is that it depicted the process as a monologue, where the risk assessor identified the problem, carries out the assessment, and informs the risk manager about the risk.  But, it doesn’t really work that way.  Risk analysis is iterative process that begins subjectively, and risk managers are always a part of it.  Formal analysis tends to bring more people, with an interest in the issue (“stakeholders”) into the decision process, including laypeople who may also vote.  In fact, that is a main reason for doing it. So, yes, communication is very important every step of the way, but it needs to be a conversation.  Monologues can kill a conversation, and they can also kill a risk analysis.

References

Kaplan, S (1997).  The Words of Risk Analysis.  Risk Anal 17:407-411.

Slovic, P (2006).  Risk Perception and Affect.  Current Directions in Psychological Science 15: 322-325.

World Health Organization (2005).  Effective Media Communication during Public Health Emergencies.  A WHO Handbook.

Official Post Soundtrack

Pink Floyd (1975).  Dogs, Pigs (Three Different Ones), and Sheep.  In: Animals, Tracks 2-4.

Post Notes.

Thesis Post #38, on the Risk Assessment Paradigm thread.

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