1. Rank the seriousness of environmental, health, or safety risks. (1) Heads of regulatory agencies involved in the regulation of environmental, health, or safety risks should direct their agencies to rank the seriousness of those risks to permit better prioritization of their regulatory agendas. This is consistent with the new regulatory review executive order, which will require agencies to consider relative risks of different substances or activities within their jurisdictions. How that prioritization can best be accomplished should be left to individual agencies. EPA's initial use of its program managers with a review by outside experts assembled by its Science Advisory Board has worked well. An alternate approach was espoused by a recent study by the Administrative Conference of the U.S. The study, done at OSHA's request, urged that agency to establish a formal prioritization committee staffed by politically sensitive technical experts who would serve staggered terms and be eligible for reappointment.[Endnote 23] Agencies should compare their own resource allocations with their internal risk rankings. Agencies should coordinate their development of risk prioritization processes and standards through the Regulatory Coordinating Group. Once risk lists are better developed and tested, they should be compared and possibly even coordinated across agency lines. No one can pretend, however, that this will be an easy task. Analytical methodologies and basic data must be improved, and public perceptions of risk (which often differ markedly from that of scientists) must be factored into the equation.[Endnote 24] Comparing various types of health risks with disparate impacts on different populations (or human health concerns with degradation of ecosystems) requires value judgments that may be impossible to quantify. Thus, precision in rankings may be unattainable. But ranking of risks into high, medium and low categories is realistic. The payoffs from such prioritization should far exceed the cost of the undertaking. It would inform the legislative process (since agency priorities are largely statute-driven), the budget process, the interagency coordination process, and ultimately, the public's understanding of risk.[Endnote 25] Endnotes 23. Administrative Conference of the U.S., Recommendation 87-1, "Priority Setting and Management of Rulemaking by the Occupational Safety and Health Administration," 1 C.F.R. 305.87-1, 52 Federal Register 23,629 (June 24, 1987); derived from Shapiro and McGarity, supra note 19, pp. 18-23. 24. See note 8 above. 25. Congress and agencies often complain that long- range plans cannot be followed because the crisis of the day dictates congressional policy, which in turn establishes regulatory mandates. Political responsiveness to mood swings in the American Public, coupled with paralysis in the institutions of government, makes it very difficult to address problems requiring a steady, sustained, and unphotogenic response. A panel of The National Academy of Public Administration, Beyond Distrust: Building Bridges Between Congress and the Executive (Washington, D.C., January 1992), p. 76. To move away from a situation where the crisis of the minute dictates long-term policy, the public needs to be better educated about the problems facing the country. Reports of a study done by the Public Agenda Foundation, founded by Cyrus Vance, demonstrated that when members of the public were given short, balanced presentations on solid waste and global warming issues, they were able to grasp the scientific issues. Exposure to these presentations changed their views on how the issues should be handled to parallel the experts' views more closely. Carnegie Commission on Science, Technology, and Government, Risk and the Environment: Improving Regulatory Decision Making (Washington, D.C., June 1993), p. 92-93.
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