Valuing Health Risks, Costs, and Benefits for Environmental Decision Making Report of a Conference (1990) / Chapter Skim
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6. Environmental Policy Making: Act Now or Wait for More Information?
6. Environmental Policy Making: Act Now or Wait for More Information?
Pages 107-133
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From page 107... ...
If the regulatory agency decides to act now, its experience with implementation may be informative about the costs and benefits of later policy choices, including future rescission of the regulatory action. In deciding to act now, the environmental decision maker thus needs to assess the future benefits and costs of correcting or rescinding policy mistakes.
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From page 108... ...
With the extreme uncertainties encountered in environmental decisions, however, new research findings can pose unexpected contradictions, thus enhancing rather than reducing uncertainty. My task in this paper is to explore, at least in a preliminary way, these dynamic complications of environmental policy making.
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From page 109... ...
In general, my analysis points toward a style of regulation in which agencies take small, incremental regulatory steps at the early stages of a problem. These small steps would be designed to impose minimal sunken investments in compliance and still provide essential information on the uncertain benefits and costs of intervention.
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From page 110... ...
The benefits of a determination that smoking causes lung cancer, Passey argued, did not outweigh the costs of "scaring" the public. The cancer risks of saccharin, Isselbacher contended, were outweighed by its benefits as a nonnutritive sweetener.
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From page 111... ...
The critical issue in applying the economic models, however, is the validity of their assumption of irreversibility. It is counterproductive to jump to label an environmental regulation as irreversible until the sunken costs that must be expended to comply with the regulation are actually measured.
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From page 112... ...
WAITING AND SUNKEN COSTS The argument in favor of regulatory delay, we have seen, hinges critically on the proposition that government intervention may impose irreversible, sunken costs on private agents. In this section, I suggest that the irreversibility argument can be turned upside down: waiting can have equally irreversible consequences.
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From page 113... ...
These particulate emissions are further known to contain carcinogenic polyaromatic hydrocarbons. Yet, there has been little sound epidemiological evidence available on the cancer risks of workers exposed to such emissions.
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From page 114... ...
With virtually no solid epidemiological evidence, however, the agency could not draw definite conclusions about the extent of human cancer risk. From a purely scientific standpoint, the prudent decision was to wait for the results of newly commissioned epidemiological studies.
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From page 115... ...
Hence, car makers had a strong incentive to accelerate their investments in diesel technology; that is, to build up their sunken costs as rapidly as possible. While EPA and some auto companies were conducting their own biological research, information on the likely pace of such research was common knowledge.
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From page 116... ...
Therefore, EPA no longer believes that ground water contamination should be a reason for classifying cyanazine for Restricted Use. Therefore, all cyanazine labels will include a statement that cyanazine products have been classified for Restricted Use only because cyanazine has caused birth defects in laboratory animals.
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From page 117... ...
Data on EDB's acute and subacute toxicity go back to the early 20th century. The evidence on EDB arose from reports of accidental human exposure and from studies of ingestion, inhalation, and decimal exposure in various laboratory animals.
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From page 118... ...
Aman reports acute toxicity of EDB by oral administration in rats and guinea pigs. EDB comes into widespread use for quarantine treatments of imported fruits and vegetables, control of interstate movement of insect pests, fumigation of grain, spot fumigation of milling machinery, and soil fumigation.
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From page 119... ...
report additonal results of NCI oral gavage study in rats and mice. EPA study shows gasoline station exposures to EDB in the range of 0.01 parts per billion and manufacturing site exposures in the range of 10 to 15 parts per billion.
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From page 120... ...
In a risk assessment based on the National Cancer Institute (NCI) oral gavage study, EPA's Carcinogen Assessment Group (CAG)
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From page 121... ...
121 , Year Scientific Developments Regulatory Developments counts compared favorably to those of the general population. Trend of sperm counts in relation to EDB exposure is found but is of questionable significance.
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From page 122... ...
EPA's CAG issues its cancer risk assessment, based on a one-hit mathematical model; the estimated lifetime cancer risk of the dietary burden of EDB is estimated at 3.3 per 10,000. EPA commissions a groundwater contamination study by the California Department of Food and Agriculture (CDFA)
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From page 123... ...
SRI International publishes a NIOSHcommissioned risk assessment based on NCI and NIOSH inhalation studies in rats and mice (June) ; chronic exposure to 130 ppb is predicted to yield 4-26 percent lifetime human cancer risk.
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From page 124... ...
risk assessment of exposures to EDB residues in consumable grain products, based on NCI oral gavage assay and assumptions of no further grain fumigation and of the depletion of EDB in grain stores by 1986; the upper limit of lifetime cancer is estimated to be 1 in 4 million. Temple, Barker & Sloane, Inc., and Economic Perspectives, Inc.
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From page 125... ...
This changing dosage schedule complicated CAG's attempts to extrapolate from high-dose to low-dose effects and risks. The CAG analysis also predicted a substantial cancer risk from long-term EDB exposures at the levels seen among chemical workers; limited surveys of EDB-exposed workers, however, showed no evidence of a significant cancer increase.
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From page 126... ...
Based on the new exposure data, as well as a reanalysis of the NCI oral gavage experiment, CAG revised the estimated lifetime risk from dietary EDB to 0.3 percent. In February 1984, the agency suspended further use of EDB in the production of grain products, although it did not order an immediate ban on the sale of all EDB-containing products.
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From page 127... ...
Had EPA accelerated the information-gathering process, especially in the measurement of food residues and groundwater contamination, less extreme measures might have been necessary. By 1984, the sunken investment in EDB had become enormous: $29 billion in grain stocks and $4.3 billion in manufacturer and retail inventories of grain products and baked goods.
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From page 128... ...
Thus, laboratory experiments and meteorologic modeling can offer only imprecise gauges of the aggregate effect on acid rain of curbing sulfur oxide emissions. Measurement of individual tail pipe emissions, in combination with dispersion modeling, may be inadequate to predict the aggregate effect of installing auto pollution control devices.
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From page 129... ...
Thereafter, CFC use in propellants declined markedly. Largely in response to a series of National Research Council studies in the late 1970s, in 1980, EPA issued an Advance Notice of Proposed Rulemaking under the Clean Air Act.
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From page 130... ...
Ground-based and satellite measurements now suggest a 3-5 percent annual decline during the 1980s. As in the case of the Antarctic ozone hole, these measurements fall outside of the uncertainty bounds computed from current atmospheric models, which predict that column ozone should not have decined by even 1 percent.
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From page 131... ...
These small steps would be designed to impose minimal sunken investments in compliance, yet provide essential information on the uncertain benefits and costs of intervention. The supporting evidence for the success of this style of regulation, however, has been largely anecdotal.
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From page 132... ...
1983 Diesel emissions and lung cancer. Risk Analysis 3:83-100.
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From page 133... ...
:14151. 1987a Preliminary determination to cancel registrations of cyanazine products unless the terms and conditions of the registration are modified; availability of technical support document and draft notice of intent to cancel.
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