Risk Management: Gone Too Far?

• Author: Oliver Houck
• Pages: 1-6

1

Risk Management:

Gone Too Far?

By Oliver Houck

Breaking t he Vicious Circle, by Stephen Breyer. Harvard Universit y

Press. 144 pages.

From the March/ April 1994 issue of The Environme ntal Forum.

Breaking the Vicious Circle is a guided

tour t hrough t he woods of risk man-

agement. e decisions of the EPA, the

Food and Drug Administration, and more than

a dozen other federal agencies on safety lev-

els for toxic discharges, automobile bumpers,

food coloring, and other haz ards of contem-

porary life are technical, c onfusing, bizarrely

disparate—and extremely consequential.

ese decisions call for— or avoid—the

expenditure of big buck s to reduce risks from

waste sites, water pollutants, paint pigments,

and aerosols. ey are often based on a smat-

tering of epidemiological studies (e.g., 15 years

ago, in Turkey), extrapolations from labo-

ratory tests (e.g., on minnows or mice), and a ssumptions about doses and

responses (e.g., if 1 milligram grows tumors in mice then 100 mi lligrams

grows tumors in humans . . . ), safet y factors ( . . . but to be safe, let’s say that

10 milligrams grows tumors in humans), and exposure pathways (e.g., hypo-

thetical individuals at t he fenceline breathing .01 milligrams for 70 years).

Anyone visiting these woods is left wide-eyed in wonder and, with whatever

energy remains, groping for a better way.

Stephen Breyer, who sits on the First Circuit Court of Appeals, conducts

this tour in a concise, readable, and knowledgeable way, and goes on to

dare a solution. e book is divided into three parts, and its depict ion, in

part one, of the uncertaint y of risk analysis and t he inequalit y among risk

management conclusions is famil iar ground to a cionados of this eld, but