# 6.6. Risk management and risk communication

Date uploaded: 21st November 2024

Author: Ad Ragas

Reviewers: Herman Eijsackers

Learning objectives

After learning this paragraph, you should be able to:

- indicate which stakeholders are involved in chemical risk assessment and what their interests are;
- characterize the main policy principles used in chemical risk management;
- outline the main characteristics of the IRGC framework.

Keywords: risk management, DPSIR, stakeholders, ALARA, precautionary principle,

Chemical risk management is the process that aims to control the risks caused by the production and use of chemicals in society. In order to understand the risk management process, it is important to understand the interests and stakeholders involved in the production and use of chemicals on the one side and the adverse effects of chemicals on the other. This can be illustrated with the DPSIR chain that was introduced in section 1.2.

Figure 1: The processes, interests and stakeholders involved in a chemical risk issue, illustrated by means of the DPSIR chain. White boxes with the solid lines represent the DPSIR chain, red boxes represent the main stakeholders, and green boxes represent the associated and conflicting values and interests of the stakeholders.

The DPSIR in Figure 1 shows that there are different groups in society that have an interest in the production and use of chemicals, i.e. the consumers that are using the products in which these chemicals are contained and the producers and retailers that make money out of the production and sale of these products. On the other hand, there are stakeholders that have an interest in the endpoints that are affected by the chemicals when they reach the environment, e.g. people that work in the production, people of the general public worried about their health and people worried about ecosystem health. These stakeholders can partly overlap, e.g. the health of consumers benefitting of chemical products may be affected by their adverse impacts. However, there often is some kind of incongruity between the people benefitting and the people affected, e.g. when future generations are confronted with pollution problems caused by current generations or when people living downstream a river are confronted with the pollution caused upstream. This can result in a conflict of interests: the people affected demand action from the people benefitting. If pollution can be easily avoided this will not be a problem (after all, consumers and producers are not aiming to pollute the environment), but action is not always that simple. The government then comes into the picture as an important mediating agency since the government can define rules that all stakeholders have to adhere to. Scientists also play an important role, e.g. by studying the extent of the risks (risk assessors) and by developing interventions that can reduce risks. Risk management thus is a process that involves different stakeholders and each stakeholder has different interests and a different role to play in the process.

Linear risk management

There are different ways to organize the risk management process. The conventional way is to arrange it as a linear process, roughly consisting of the following steps:

1. recognition and definition of the risk problem, often led by the government (politicians and policy makers), sometimes after pressure from different stakeholder groups in society;
2. establishment of the nature and extent of the risk by scientists, often in isolation;
3. identification and selection of risk reduction measures (if needed), often led by the government and often in collaboration with primary stakeholders (i.e. the producers and consumers);
4. communication of the risk management strategy (i.e., the risk and risk reduction measures) to the stakeholders, including the general public. This communication process is typically led by the government and often consists of a unidirectional flow of information (primarily scientific information) from the government to the stakeholders.

This way of arranging the risk management process is strongly rooted in the belief that chemical risk is a strictly defined concept that can be objectively measured and quantified by means of scientific methods. It is reflected in many risk regulations such as the system of environmental quality standards (EQSs) of the European Water Framework Directive, exposure standards for the workplace and air quality regulations.

Risk management principles

The aim of chemical risk management is to control and reduce the risks of chemicals. A quantitative estimate of the risk is an important ingredient in this process, but definitely not the only one. Chemical risk management is often based on the application of various policy principles that can be applied in isolation or combination. Some important principles in the risk management of chemicals include:

- As Low As Reasonably Achievable (ALARA). This principle stresses the fact that environmental pollution should be avoided whenever feasible. The principle is often applied regardless of the risk caused by a pollutant and plays an important role in environmental licensing of production facilities.
- Polluter Pays Principle (PPP). This principle states that the polluter should pay for polluting the environment. This principle forms the basis for the taxation of polluting activities such as waste disposal and sewer discharges. Ideally, these taxes should then be used to prevent and reduce environmental contamination (e.g. to build and maintain wastewater treatment plants; WWTPs), but this is not always the case.
- Precautionary Principle. This is probably one of the most debated principles when it comes to environmental regulation and it is also highly relevant for chemical risk assessment. There are various definitions of the precautionary principle, but the most widely accepted definition states that scientific certainty is not required before taking preventive measures. The precautionary principle thus is a way to deal with uncertainty. It enables policy makers to take preventive action in the absence of absolute certainty. However, there must be a legitimate reason for concern. This is also what complicates operationalisation of the precautionary principle: when is there “sufficient reason for concern to take preventive action”? This ultimately is a normative choice that strongly depends on the stakes and interests involved.
- No data, no market. This policy principle is one of the fundamental principles underlying Europe’s chemical legislation (REACH; section 6.5). It is related to the polluter pays principle in the sense that it puts the burden of proof that a risk is acceptable (and the associated costs) on the shoulders of those who produce or import a chemical. The principle is increasingly used in environmental legislation: producers should prove that the chemicals and products that they put on the market are safe and sustainable.

The IRGC framework

Over the last few decades, the belief that risk is a strictly defined concept that can be objectively quantified is increasingly being challenged. The fact that chemical risk not really is a strictly defined concept becomes clear as one realizes that mixture effects have been ignored for decades but are now increasingly being included in chemical risk assessments. And not all stakeholders value risks in the same way as is explained in section 6.7 on risk perception. Although the scientists and risk assessors performing the risk assessment generally do their best to assess risk as objectively as possible, they must make subjective assumptions. Endpoints, unacceptable effects, magnitude of uncertainty factors are controversial topics and based on implicit political choices. Questions about risk often have no scientific answers or the answers are multiple and contestable. This has led to suggestions to rearrange the traditional linear risk management process into a process in which stakeholders are much more involved. One of these suggestions is the framework developed by International Risk Governance Council (Figure 2; IRGC, 2017). This framework provides guidance for early identification and handling of risks, involving multiple stakeholders. It recommends an inclusive approach to frame, assess, evaluate, manage and communicate important risk issues, often marked by complexity, uncertainty and ambiguity. The framework is generic and can be tailored to various risks and organisations. The framework comprises four interlinked elements, and three cross-cutting aspects:

1. Pre-assessment – Identification and framing.

- Leads to framing the risk, early warning, and preparations for handling it,
- Involves relevant actors and stakeholder groups, so as to capture the various perspectives on the risk, its associated opportunities, and potential strategies for addressing it.

2. Appraisal – Assessing the technical and perceived causes and consequences of the risk.

- Develops and synthesises the knowledge base for the decision on whether or not a risk should be taken and/or managed and, if so,
- Identifies and selects what options may be available for preventing, mitigating, adapting to or sharing the risk.

3. Characterisation and evaluation – Making a judgement about the risk and the need to manage it.

- Process of comparing the outcome of risk appraisal (risk and concern assessment) with specific criteria,
- Determines the significance and acceptability of the risk, and
- Prepares decisions.

4. Management – Deciding on and implementing risk management options.

- Designs and implements the actions and remedies required to avoid, reduce (prevent, adapt, mitigate), transfer or retain the risks.

5. Cross-cutting aspects – Communicating, engaging with stakeholders, considering the context.

- Crucial role of open, transparent and inclusive communication,
- Importance of engaging stakeholders to both assess and manage risks, and
- Need to deal with risk in a way that fully accounts for the societal context of both the risk and the decision that will be taken.

Figure 2: The risk governance framework of the IRGC (2017).

References

IRGC [International Risk Governance Council], 2017. Introduction to the IRGC risk governance framework. Revised version. Lausanne: EPFL International Risk Governance Center.