Iteration
To iterate or not to iterate, that is the question. Whether tis nobler to damn the torpedoes or
to consider other options and opinions. Like
personal decisions, regulatory policy decisions are always plagued by this dilemma
to some degree: The risk assessment is never really done until the decision has
been made. Formal decision processes that are molded by
institutionalized strictures are, of course, usually not flexible enough to go
either way. Therefore, they either
advocate staying or going. Since the objective is usually to make policy
rather than not, usually it’s the latter.
For example, consider the 1983 NRC risk assessment paradigm. It’s a linear process that starts with
research that progresses to risk assessment which then gives way to risk management:
That’s the monologue version of public decision making. The scientists give the risk assessors the data, the risk assessors analyze the data and give the risk managers the risk estimates, and the risk managers decide what to do. That characterization sounds so good, it gets repeated quite often. But, for better or for worse, that’s often nothing like what really happens. For example, a different NRC committee depicted the decision process like this:
Yeah, it’s a mess – but it really is a better characterization of what actually
happens sometimes. In any case, the main
feature of the 1996 version that is worth noting is that there are “feedback loops” that make the
process somewhat circular instead of linear.
Or in other words, instead of a monologue, the risk assessment process
is comprised of one or more dialogues. In
order to simplify the formal representation a little bit, here is a more basic adaptation
of the 1983 paradigm with dialogue included:
With this simpler representation, a couple of basic points
can be made about risk assessment when it is viewed as an iterative dialogue
rather than a linear monologue:
- The Risk Assessment process does NOT begin with scientific research. In fact, since every formal risk assessment is preceded by a subjective one, it may not be possible to assign a starting point. At best, formal risk assessments serve to refine decisions rather than to create them from nothing. At worst, they sell bad decisions.
- The actual risk assessment part of the process sits at the juncture of two very different sorts of dialogues. The policy dialogue is concerned with what actions are to be taken as a matter of public policy. The scientific dialogue is concerned with the development and establishment of scientific dialog. At best, risk assessment serves as a science-policy interface. At worst, risk assessment is where scientific illiteracy meets political naiveté and everything comes to a grinding halt.
Scientific Role Playing
While there certainly are some minor differences between
personal and public decision making, they are both comprised of something like
the policy loop and the science loop.
For example, a philosopher would call the science loop “epistemology”
and the policy loop “ethics”. Yet the
1983 monologue version of the decision paradigm presupposes that Risk Assessment
starts with unbiased ethics-free scientific research. But, unless it is totally useless, science is
never conducted without a purpose. Well,
that’s what taxpayers are told anyway.
More to the point, every research program has an ethical
underpinning of some sort. Those value judgments may come from the
scientists themselves or they may come from whomever is paying for the
research. The monologue ignores all
that. If research is designed to determine
an exposure with an acceptable risk, then the ethical issues must be resolved
before hand. Who does that? Someone who wears a lab coat probably had a
lot to do with it. Scientific research often
comes with a political viewpoint attached.
While scientists are not devoid of ethical judgment, with
some effort science can be extracted from the scientist – it just takes a
little cross-examination, scientific dialog, or peer review. In fact, that is what good scientists do;
they argue and they criticize one another incessantly. A good scientific dialogue will expose
personal bias. But, as a formal representation
of the decision process, the monologue doesn’t recognize that. Therefore, the monologue engenders and
empowers advocates in lab coats who are ready to play the science card at the
drop of a hat. They may call for peer
review, but only when a majority of the peers have the right moral principles. But, that’s not good science. It’s probably not good policy either.
The Political Narrative
The fact of the matter is that scientists don’t really need
formal decision paradigms, but
politicians do. For better or for worse,
one of the tasks associated with running a government is convincing the
citizens that the government is doing what it should be doing. As a result, decision paradigms often
function as political rhetoric. The
rhetoric is often not the least bit subtle.
For example, appendix N of the 1994 NAS treatment of risk assessment pits
a monologue version of risk assessment that enforces the use of conservative
assumptions vs a dialogue version that embraces the acknowledgement of scientific
uncertainties. If that isn’t politics, what is?
The monologue version of risk assessment is essentially
autocratic. It embraces the creation and
use of a process that can be directed and controlled. As a corollary, it tends to create an
Us-vs-Them mentality: Either you support
the process or you don’t. For example,
if the government is going to ensure the safety of the food supply, then the
government needs to be in control of the risk assessment process. right? Perhaps not.
The dialogue version of risk assessment is the democratic
ideal: Free speech, public participation,
two heads are better than one, yada yada. But, as with the 1996 figure above, it’s a
mess; hardly a process at all. Then there is the iteration problem: Once you start talking, when do you stop? In its purest form, the dialogue basically always
results in paralysis by analysis. As the 1996 NAS report noted, the big trick
with dialogues is coming to closure. Deadlines can help a lot in that regard.
References
National Research Council
(1983). Risk
Assessment in the Federal Government: Managing the Process. National Academy Press, Washington, DC.
National Research Council
(1994). Science
and Judgment in Risk Assessment. National
Academy Press, Washington, DC.
National Research Council
(1996). Understanding
Risk: Informing Decisions in a Democratic Society. National Academy Press, Washington, DC.
Official Post Soundtrack
Post Notes
Thesis Post #49. A sequel to "The Risk Assessment Paradigm", but also related to the last post on objectivity.
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