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Interdepartmental Liaison Group on Risk Assessment Use of Risk Assessment (UK-ILGRA) within Government Departments

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Chapter Three

Analysis

Common Themes

The survey on the use of risk assessment confirmed that the use of risk assessment has not been developed systematically in Government, but has simply evolved within Departments. Yet, there is nevertheless, considerable agreement on what a risk assessment involves and its application in general. For example, there is broad general agreement among Departments on:

The basic principles that should govern the integration of risk assessment into policy formulation and the decision-making processes.

Departments agree that risk assessment and risk management techniques should be used for setting out priorities; identifying the merits of options available and evaluating the effectiveness of measures adopted. Indeed Table 1 shows that an assessment of risks underpins many of the functions undertaken by Government notably:

Departments agree that risk assessment is a useful tool in carrying out the above functions because it:

Typical examples of the integration of risk assessment into policy formulation and the decision-making processes include:

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The essential elements of the methodology for assessing risks

Departments agree that:

- assessing risks entails:the identification of hazards;the identification of the population(s) exposed;an estimation of the risks to the population(s) exposed.

- the results of such assessments, combined with the assessment of other factors such as the costs and benefits of the available options, the degree to which perceptions of risks should be taken into account, the state of available technology etc., should lead to decisions to the extent the risks should be controlled, and if so, when and how.

Some Departments have further subdivided some of the steps in (i) above, eg. some have broken the first step into hazard characterisation and hazard identification. These variations reflect refinements rather than disagreements.

Moreover, Departments agree that:

The need for criteria to decide whether a risk is great enough to warrant attention and to judge the amount of resources that should be spent on reducing it.

Most Departments agree that measures for controlling risks should be proportional to the risks and that perception of the risk needs to be taken into account since, in a society, it is a question of values which decides:

Indeed, there are instances of Departments using the criteria described in Chapter 1 paras 36-37. For example:

It was also pointed out that if a cost benefit-based criterion was always used in place of others this would have the advantage of resulting in the maximisation of net benefits. However, the general view amongst Departments was that equity based criteria had a role to play to accommodate society's preferences, particularly in Government's role as a regulator. Moreover, CBA techniques have not reached the stage where their application would truly maximise benefits. There were difficulties in putting monetary values on many kinds of detriments and certain benefits. There were also many uncertainties. The relationship between costs and benefits is rarely linear and indeed is usually unknown. This does not detract from the fact that CBA techniques are very useful and that despite the above difficulties their use is most likely to ensure that regulation is proportionate to its costs and benefits and so should be used wherever possible.

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Value of a Statistical Life

Most Departments when undertaking CBAs use the DoT road improvement scheme figure for a statistical life (currently about £¾m) as a baseline. However, several Departments like HSE (paras 65-69), see this value as too low for risks with more undesirable characteristics such uncertainty or lack of control by those at risk.

  1. An inter-departmental research project is looking at these issues, including people's willingness to pay in relation to various circumstances and type of accident.

The principles governing good risk communication

At present, all Departments agree that the objectives of risk communication are to:

  1. promote and inform the public about health and safety;
  2. share power between the Government and the public;
  3. improve mutual understanding of public and Government attitudes to policy making about health, safety and the environment, eg by identifying the reasons for differing opinions and seeking ways to adopt decisions which can be accepted by the majority of people involved; and
  4. develop effective alternatives to direct regulatory control.
  5. influence human behaviour in a positive manner. The Health of the Nation White Paper for example, seeks to persuade people to lead healthier lives by explaining the risks of smoking, lack of exercise, high fat diet etc.

Towards more coherence and consistency

This commonality of approaches within Departments is very encouraging. However, the survey has also revealed areas where greater coherence and consistency within Government would have definite and tangible advantages. This does not mean that Departments should adopt the same approach or methods. What is important is that policies and methodologies embraced by Departments are consistent with each other. Areas where greater coherence and consistency are desirable are examined below and the further guidance which the Deregulation Unit is preparing (see para 95) will build on this commonality .

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Common Methodology

Many Departments have pointed out that risks do not usually apply to just a single receptor (eg, the environment, workers, the public, etc). However, the boundaries of responsibility between Government Departments often appear to assume that they do. To prevent inconsistencies and the imposition of unreasonable burdens on those who have to carry out and act on risk assessments, it is important that Departments:

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Common Terminology

Many Departments have identified the lack of a common terminology as a major obstacle to the promotion and understanding of the concept of risk assessment and believe that the adoption of a common terminology would:

The Relationship Between CBA and Risk Assessment

The outcome of a risk assessment essentially leads to a judgement on the controls to be applied to a particular issue. Since a judgement necessarily involves consideration of the resources in overall monetary terms that should be devoted to it, risk assessment and CBA are interlinked. This gives rise to overlapping methodological issues eg:

There are differences between Departments on the methodologies they have adopted and these can lead departments to reach different conclusions on the extent of the measures necessary for controlling the same risks.

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Exchange of Data and Information

Facts and data on hazards and risk are often hard to come by. Science and statistics by their very nature are provisional, with new findings and new compilations driving old ones out after a time. In short, even when data exists, it has to be recovered, organised and updated.

A greater exchange of information and data between Departments - and better means of achieving this objective - would no doubt help. For example at present:

Risk Ranking

One of the great challenges that the Government has encountered as part of its deregulation initiative is how to set priorities for the regulation of risks. Some of the difficulties were ascribed to organisational fragmentation within Departments but the greatest problems experienced seem to be concerned with the need to get the right balance between real risks and perceived risks.

It is suggested that Departments would benefit from drawing up common criteria for comparing risks (both real and perceived) and ranking the risks they administer in broad categories. Common strategies could then be developed for addressing risks of high priority. Such exercises should be repeated periodically to take account of new information, changes in public attitudes and available technology. The HSE has already provided the lead with its Health Risk Reviews.

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Co-operation on Research and Development

Departments undertake or commission a considerable amount of research pertinent to health and safety, but it tends to be compartmentalised. In view of the interdisciplinary nature of risk assessment there is a need to improve collaboration between Departments. The fact that Departments may have different policy objectives, timescales, budgets and priorities should not be an insurmountable problem. The 1995 Forward Look of Government Expenditure on Science and Technology describes a proposal for strategic collaboration between Departments in the area of risk assessment and toxicology.

ILGRA has made a start at compiling a list of risk assessment research carried out by Departments and plans to keep it up to date.

Risk Communication

All Departments stressed the need for good risk communication and the urgent need to improve Departments' performance in this area. Communicating risks is becoming more and more difficult as the public agenda gets overcrowded. In addition to current scares such as AIDS, global warming or the likelihood of a plague epidemic, pressure groups and the media have tended to exaggerate insignificant risks, often at the expense of ignoring larger more common-place ones.

Departments agree that, as a result, the public is confused and treats Government assurances of the safety of, for example, pesticides, food additives and nuclear power stations with considerable scepticism. In the wake of recent scares such as salmonella in eggs or BSE, a Government-wide strategy on risk communication would be beneficial. Indeed, recent research suggests that the public can be very sensible about risk when given balanced information and enough time to reflect on it. Often what seems an unreasonable reaction on their part may disappear when they are exposed to the science underlying the risks. In contrast, nowadays the public in general are rarely aware how risk estimates are arrived at; that often they represent a "worst case scenario" or indeed why in many instances it is worth tolerating the risks associated with certain activities in view of their benefits.

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Common UK Approach to Risk Assessment at an International Level

  1. Risk assessment now features in many standards and regulations emanating from European and International bodies. However, it is only relatively recently that the European Council has introduced the concept in directives. It can therefore be anticipated that the European Commission is likely to come up with proposals to harmonise policies and strategies for assessing risks across Member States. A common framework within departments on the scientific and policy rules underpinning risk assessment and risk management would without doubt help to improve UK's effectiveness in contributing to the development of EU and international standards.

Openness

Departments agree with the principle that, in the field of health and safety, openness and international co-operation are important because of the direct contribution to the ultimate objective of improving performance but also because of the potential for health and safety considerations to be used as a barrier to trade.

However, Departments vary as to their degree of openness. There is a need for Departments to develop a common policy which subscribes to complete openness, moderated only to the minimum extent necessary to prevent undesirable outcomes, such as the prevention of commercial development or possible reduction in the flow of information through the health and safety system.

Steps for Greater Consistency

The survey on risk assessment has revealed that Departments have reached a cross-roads in health and safety and environmental risk-related policy making. The trend for goal-setting as opposed to prescriptive legislation is now firmly established in the UK and slowly gaining ground in directives emanating from the European Union dealing with healthier places of work, safer commercial products and a cleaner environment.

Yet, risk problems have never seemed more intractable. The most obvious ones have already been tackled. Those that remain tend to be harder to be characterised precisely. For example, despite considerable research, the carcinogen(s) associated with certain industrial processes known to give rise to occupational cancer, have not been identified. New problems that were unknown or seemed peripheral one or two decades ago have emerged and gained prominence. Typical examples include the interface between man and new technologies, global warming, ozone depletion and the need to embrace the goal of sustainable development in the wake of the 1992 United Nations conference on Environment and Development in Rio de Janeiro. It can be anticipated that as these issues are addressed, both at the international, European and national level, the regulatory agenda will continue to change rapidly and will have to be tackled by all levels of Government and industry working closely together to make progress.

There has therefore never been a more appropriate time for Departments to develop together consistent approaches to the issues identified in this report. Indeed the Technology Foresight Steering Group in its report "Progress for Partnership, May 1995" identified risk and risk management as a generic science and technology priority.

The Government, in its 1995 "Forward Look of Government-funded Science, Engineering and Technology, has endorsed the recommendation that ILGRA should look at these issues and put forward proposals on how the objectives identified above for achieving greater coherence can be achieved. In short, ILGRA while continuing with its role in sharing experience and data will also be exploring the possibility of developing risk related protocols for integrating the various inputs (science, engineering, economics, people perceptions, etc) into policy decisions and the regulatory framework. It plans to do so in close co-operation with the Deregulation Unit to ensure that its work takes full account of the Government's Deregulation Initiative.

Updated 2011-05-04