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population) including: a) communities of color and low-income communities historically subjected to environmental, social, and economic injustice; b) particularly susceptible sub-populations such as pregnant woman, children, the elderly, and populations exposed to multiple hazards; and c) risks to workers, as well as the general population. It should be recognized that it is impossible to develop useful ordinal rankings of sites or cleanup activities based solely on risk or risk reduction potential. At best, the Committee believes risk assessments can be used to categorize environmental contamination problems into broad groupings such as those that pose high, medium, or low risk. It may also be possible to group and compare cleanup actions into those that may result in high, medium or low risk reduction per dollar of expenditure. Further ranking of contaminated areas or actions using risk assessments makes consideration of other important factors (described in Principle 10b below and Chapter 5) difficult if not impossible”. On page 25 (PDF — 44) the 1996 report cautions in bold text that “fiscal constraints,” presumably referring to budgetary considerations, should not be used to justify not taking appropriate environmental remediation measures: “The Committee believes that fiscal constraints do not justify failing to take actions to protect human health and environment, but may result in the need to set priorities about what cleanup actions can occur in any given year. As discussed further in Chapter 5, risk to human health or its corollary, protection of human health is, |
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at many sites, only a starting point for establishing cleanup funding priorities. The Committee also believes that in many other instances protection of the environment is the appropriate starting point for establishing cleanup funding priorities. Furthermore, in other cases, protection of human health and the environment is the appropriate starting point for establishing funding priorities for cleanup. The Committee strongly recommends that in those instances where protection of the environment is not used as a starting point for establishing cleanup funding priorities, it should be considered as one of the factors that are listed below. Thus, while the Committee believes the comparison of human health and environmental risk and risk reduction potentialis appropriate in setting priorities for federal facility cleanups, they are not the only factors, andrisk must be viewed in the context of other social values, environmental goals, and economic benefits”. The 1996 report then elaborates by citing on page 26 (PDF—46) the following types of factors which should be considered when determining cleanup priorities: “Some of the other factors that should be considered in setting priorities for federal facility environmental cleanup include, but are not limited to:
a) cultural, social, and economic factors, including environmental justice considerations; b) potential or future use of the facility, its effect on the local communities' economy, vitality, livability and environmental quality; |
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a) There are scientific uncertainties associated with the myriad of assumptions imbedded in these analytical tools. Moreover, it should be recognized that there are often limitations on the availability and quality of data necessary to make effective use of such tools. Risk assessment reports should clearly delineate these limitations in laymen's terms as part of the analysis. b) Stakeholders should be involved in both the analysis of risk and risk reduction potential at the front end, including exposure assessments, as well as the risk management and broader priority setting decisions that flow from such analyses. Such involvement should be accomplished in a way that does not overly complicate the nature of the data and methodologies being used or the decisions being made on the basis of these analyses. This involvement should be encouraged to focus the effort and maximize the benefit of the study. c) The assumptions used in conducting risk assessments should be communicated at the front end so the results may be better understood. Overly certain or emphatic statements concerning the results of any effort to analyze or compare risk or risk reduction potential such as those offering unqualified numerical precision should be avoided. d) Risk assessments should analyze appropriate carcinogenic and noncarcinogenic effects when evaluating the human health effects resulting from expected exposures. If and when risk assessments are used, they should be used as a tool to help assess the risk to diverse populations (rather than averaging risks across the general |
FFERDC Guidance (pre 2000)
(CONT’D FROM P. 18)
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