RE: Risk Reduction

[Jerry Filbin <filbin.gerald@epa.gov>]

Lenny Seigel raises several interesting questions about risk reduction.  The question about acceptable levels of risk ("how safe is safe, how clean is clean") is one EPA has been struggling with in a regulatory and sound science arena for a long time.  Many adaptations of our regulatory programs (such as brownfields for instance) try to refine our use of scientific assessments in decision making in response to concerns and criticisms that EPA and its state partners were identifying remediation targets were too costly and provided no extra margin of safety for the likely re-use of the property.  In this sense, most of our major programs' regulatory action do focus on risk reduction rather than total risk elimination.  In many instances the acceptable level of risk are identified in statute or in regulation (e.g., for drinking water, no incidence of waterborne illness or death above 1 in 100,000 people in a population; for surface water, no illnesses or death from fish consumption above 1 in 1,000,000 people in a population) and EPA must carefully consider costs in many instances for incremental reductions of risk.  I think that this is the case in Superfund remediations - where the EPA must consider incremental cost in selecting its clean-up approaches.