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6 IMPLEMENTING THE NEW APPROACH
Pages 133-154

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From page 133...
... It then discusses two keys to making our approach practical: diagnosing risk decision situations in order to match the process to the needs of the situation and building the capability for implementation. PRACTICALITY There are legitimate concerns about the practicality of the analyticdeliberative approach to risk characterization presented in Chapters 3, 4, and 5.
From page 134...
... Analyzing additional dimensions of risk may seem to invite additional debate, but experience shows that extended and unproductive debates have been prompted by omissions in existing analyses. In large and complex decision exercises, risk characterizations that do not consider ecological, social, or human health outcomes that are important to some of the interested and affected parties or that are based on a process that excludes key parties can lead to court challenges and other activities that question the technical adequacy of the analyses, when the actual concern is the process or risks that were never analyzed.
From page 135...
... These dangers are sufficient in our judgment to warrant experimental efforts to provide resources to allow meaningful participation for parties that could not otherwise join effectively in deliberations. Such experimental efforts should be focused first on risk decisions that may seriously affect the parties in question.
From page 136...
... However, for most such decisionssuch as about high-level radioactive waste disposal, dioxin, and the likethe linear approach has not produced the efficient process that was hoped for, even after huge investments in risk analysis and characterization. For the vast majority of risk decisions, our approach calls for much less than the most extensive possible analytic-deliberative process, and may not add much, if anything, to the current level of effort.
From page 137...
... Although a single organization may have responsibility for risk characterization, diagnosis generally benefits from interactions of its staff with scientists, policy makers, and interested and affected parties. Diagnosis results in a provisional procedure for each step of the analytic-deliberative process leading to a risk characterization.
From page 138...
... The Risk Decision Landscape Risk decisions vary along many dimensions. Although it might be desirable to reduce these to a few, as has been done with the qualitative aspects of hazards (see Figure 2-5, p.
From page 139...
... The paradigmatic case is that of decisions associated with the Yucca Mountain site for a permanent national repository for high-level radioactive waste. Because of the size of the stakes in the ultimate decision in such an instance, risk characterization often needs to be based on extensive analysis and deliberation with broad participation or representation of the spectrum of interested and affected parties at every step of the process.
From page 140...
... Because of the potential for loss of trust, the responsible organizations should consider planning for regular review of the risk characterization routines used for informing major classes of routine, quick decisions. Many of the considerations that apply to setting up and conducting the analytic-deliberative process leading to risk characterizations for unique, wide-impact decisions apply also to reviews of routines for risk analysis or characterization.
From page 141...
... The responsible organizations should be alert to the need, especially when the likely impact of a decision or the potential for controversy is great, to design or modify aspects of the process to suit unique needs of the particular decision. As with routine decisions, any standard procedures should be periodically reviewed; as with unique, wide-impact decisions, it is important to consider instituting broadly based deliberative mechanisms in one or more of the tasks leading to a risk characterization.
From page 142...
... Consequently, it may be difficult for many of the interested and affected parties to recognize their importance and to mobilize resources to participate in the analytic-deliberative process. The responsible organizations may need to make special efforts to identify and involve the parties and to ensure broad and balanced participation.
From page 143...
... If risks appear on initial consideration to be inequitably distributed as a function of race, gender, socioeconomic status, or other factors, the diagnostic effort should lead to a conclusion that the analytic-deliberative process specifically address these issues and that the potentially affected parties participate to ensure that the process is carried out in a way they find competent and credible. Answers to diagnostic questions about the nature of the harm should reveal the kinds of human health effects and ecological impacts that may need to be characterized and the various other kinds of possible adverse outcomes that technical experts or interested and affected parties consider important.
From page 144...
... Answers to the diagnostic questions about consensus and possible omissions from analysis can suggest what will be needed for a risk char acterization to meet the likely demands on it. What kinds of analysis will the interested and affected parties demand?
From page 145...
... Issues to consider for a government agency include the agency's legislative mission; legal requirements affecting the decision-making process (e.g., Administrative Procedure Act) ; the degree to which the decision-making
From page 146...
... Staff should identify the types of decisions that will probably follow the risk characterization and consider how the particular risk characterization activity will facilitate the decision and the overall aims of the organization. It is important to also consider possible secondary and tertiary impacts of the decision, which may be of more concern to interested and affected parties than the primary one.
From page 147...
... Diagnosis should consider the possibility that some affected parties may resist participation because they believe they are more likely to achieve their desired outcomes by some other strategy, such as a legal challenge. Diagnosis should result in tentative recommendations on how to address any such problems that seem likely to become significant.
From page 148...
... We emphasize again that understanding the potential for controversy and designing an analytic-deliberative process accordingly are not enough to prevent some unwanted outcomes. Deliberations across the range of decision participants may fail to reach consensus and, sometimes, interested or affected parties may choose to exert influence indirectly and outside the officially designated process, such as through litigation, legislation, or mass media publicity.
From page 149...
... Especially when the risk analysis is expected to be complex and difficult and there is likely to be polarization and politicization about the risk decision, an understanding among both staff in the organization and the interested and affected parties that the organization is committed
From page 150...
... It must also be prepared to cope with the possibility of attempts by some of the interested and affected parties to delay a decision, and it must develop a range of strategies for reaching closure on decisions that affect the process leading to risk characterization. Broadening the process also requires new kinds of coordination between the organizational units normally responsible for risk analysis and those responsible for interactions with interested and affected parties.
From page 151...
... Some agencies consider reviewing deliberative innovations to be integral to their success and improvement (Fisher, Pavlova, and Covello, 1991; Young, Williams, and Goldberg, ~993; Crumbly, 1996~. (On organizational learning related to risk decision making, see Short and Clarke, 1992; Chess, Tamuz, and Greenberg, 1995.)
From page 152...
... We believe that asking questions like those listed below will yield valuable insights that can be used to develop realistic expectations for the analyticdeliberative process and to arrive at a working definition of success or effectiveness. Criterion Measurement procedure Getting the science right Getting the right science Getting the right participation Getting the participation right Developing accurate, balanced, and informative synthesis Ask risk analytic experts who represent the spectrum of interested and affected parties to judge the technical adequacy of the riskanalytic effort Ask representatives of the interested and affected parties how well their concerns were addressed by the scientific work that informed the decision Ask public officials and representatives of the interested and affected parties if there were other parties that should have been involved Ask representatives of the parties whether they were adequately consulted during the process; if there were specific points when they could have contributed but did not have the opportunity Ask representatives of the parties how well they understand the bases for the decision; whether they perceived any bias in information coming from the responsible organization Evaluation or feedback should take a form appropriate to the scale and nature of the analytic-deliberative process: a resource-intensive risk characterization will merit more rigorous and extensive evaluation than a more limited one.
From page 153...
... Feedback and evaluation can begin in the diagnosis phase, when the responsible organization begins to define the resources it will need to develop a risk characterization and to develop a preliminary process design. Process evaluations that seek data for midcourse corrections should be common practice.
From page 154...
... Although there is no standard procedure for doing this, organizations can benefit by asking a series of diagnostic questions when they plan the process and by keeping their diagnoses flexible and responsive to information that emerges during the process. Implementation may also require organizational efforts at staffing and training and organizational changes to permit the necessary coordination among units and to allow flexibility in the processes informing risk decisions.


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