Risk Reduction

[Lenny Siegel <lsiegel@cpeo.org>]

I'm Lenny Siegel. Nationally, my organization - the Center for Public Environmental Oversight - works with community groups on military base, brownfields, and other Superfund cleanup. I'm also a local activity in Silicon Valley.

I'd like some feedback on an idea that I've been kicking around about the dreaded four-letter word: RISK. I don't think we have the tools to adequately measure absolute risk. Often cleanup technologies don't allow us to reach "acceptable risk" levels. And I don't particular like the "risk-based" approach, in which we clean up just enough to satisfy a regulatory goal.

Therefore, I've been suggesting, instead, a focus on RISK REDUCTION. That is, we evaluate remedies based upon their ability to remove contaminants from the environment or eliminate exposure pathways. When it appears that additional time or expenditures are not continuing to reduce risk, we should stop what we're doing and consider alternatives. Such an approach should be agreed upon up front, and data collection should be designed to help analyze reduction, rather than absolute levels, of risk.