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Part VI Risk Management Risk characterization serves to inform risk management At minimum, ecological risk assessors must report the results of their risk characterization to the risk manager and any stakeholders who are involved in the decision-making process (Chapter 35) In some contexts, ecological risk assessors are also involved in the decision-making process (Chapter 36) To the extent that a formal analytical process is involved, risk assessors must, at least, present results that support that decision analysis Because decisions are based on human health, legal, economic, ethical, and political considerations as well as ecological considerations, ecological risk assessors should be prepared to help integrate all of those considerations to support the risk manager (Chapter 37 and Chapter 38) Once the management decision has been made, ecological risk assessors may be involved in monitoring the results (Chapter 39) This part of the process of environmental assessment and management is the least comfortable for most ecological risk assessors However, if they are to be successful in influencing environmental management, environmental scientists must be prepared to engage with the social sciences and deal with the politics of decision making ß 2006 by Taylor & Francis Group, LLC ß 2006 by Taylor & Francis Group, LLC 35 Reporting and Communicating Ecological Risks It may not seem very important, I know, but it is, and that’s why I’m bothering telling you so Dr Seuss It is important to distinguish the reporting of risk assessment results from communicating risks Reporting ecological risks involves creating a document that will support the decisionmaking process by providing information for cost–benefit analysts or decision analysts, by informing the decision makers, by informing stakeholders such as manufacturers and responsible parties, and by serving as a basis for defense of the decision should it be challenged in court or sent for review to the National Research Council or similar body Communicating ecological risk is a process in which risk assessors personally convey their findings to decision makers and stakeholders Risk communication may also include written products, but they should be short statements (e.g., a one-page fact sheet) to prepare the audience or for the audience members to take away as a reminder of the message Risk reporting and communication are similar in the need to convey results clearly to the intended audiences However, a report must meet the needs of all likely audiences, while oral communication should be tailored to specific audiences 35.1 REPORTING ECOLOGICAL RISKS The form in which ecological risks are reported is an oft-neglected aspect of the practice of ecological risk assessment The EPA’s guidance for risk characterization states that a report of risk assessment results must be clear, transparent, reasonable, and consistent (Science Policy Council 2000) Considerations for achieving these goals are listed in Box 35.1 However, the goals of being brief (for clarity) and transparent are conflicting If sufficient detail is presented for the reader to fully understand how the results were derived and to replicate them, the resulting multivolume report will be thicker than anyone will care to read As discussed in Chapter 5, simply justifying the assignment of distributions to parameters may result in a sizable report However, some critics have advocated more complete risk characterizations including multiple alternative risk estimates (Gray 1994) For ecological risk assessments, this means reporting not only risk estimates for all lines of evidence in all types of evidence for each endpoint, but also results for alternative assumptions within a line of evidence ß 2006 by Taylor & Francis Group, LLC BOX 35.1 Clear, Transparent, Reasonable, and Consistent Risk Characterizations For clarity: Be brief Avoid jargon Make language and organization understandable to risk managers and informed lay people Explain quantitative results Fully discuss and explain unusual issues specific to a particular risk assessment For transparency: Identify the scientific conclusions separately from policy judgments Clearly articulate major differing viewpoints or scientific judgments Define and explain the risk assessment purpose (e.g., regulatory purpose, policy analysis, priority setting) Describe the approaches and methods used Explain assumptions and biases (scientific and policy) and their influence on results For reasonableness: Integrate all components into an overall conclusion of risk that is complete, informative, and useful in decision making Acknowledge uncertainties and assumptions in a forthright manner Describe key data as experimental, state-of-the-art, or generally accepted scientific knowledge Identify reasonable alternatives and conclusions that can be derived from the data Define the level of effort (e.g., quick screen, extensive characterization) along with the reason(s) for selecting this level of effort Explain the status of peer review For consistency: Follow statutory requirements, guidelines, and precedents Describe how the risks posed by one set of stressors compare with the risks posed by a similar stressor(s) or similar environmental conditions Indicate how the strengths and limitations of the assessment compare with past assessments Source: Adapted from EPA (U.S.Environmental Protection Agency), Guidelines for Ecological Risk Assessment, EPA=630=R-95=002F, Risk Assessment Forum, Washington, DC, 1998; and Science Policy Council, Risk Characterization Handbook, EPA 100-B-00-002, US Environmental Protection Agency, Washington, DC, 2000 The usual solution to this conflict between brevity and transparency is the executive summary Unfortunately, executive summaries attempt to summarize the entire assessment and are seldom sufficient to stand alone if the ‘‘executive’’ is the risk manager A report of results that neglected methods but presented risks in adequate detail for decision making would probably be more useful in most cases In addition to summarizing the results, a report to the risk manager should explain the major issues, any controversies, and relevant precedents Ideally, the contents and level of detail would be worked out between the risk assessors ß 2006 by Taylor & Francis Group, LLC and risk manager Routine assessments, such as those for new chemicals, may have a standard form or format for reporting to the risk manager The needs of users other than the decision maker constitute a more serious conflict with the call for brevity Cost–benefit analysts or decision analysts need detailed results to support their analyses Risk assessments prepared by a responsible party must present data and methods in detail so that regulators can review their acceptability Risk assessments prepared by regulators must present data and methods in sufficient detail that the responsible party can review their acceptability In either case, the report must be sufficiently detailed to withstand legal scrutiny As a result, the report of a complex ecological risk assessment may fill a library shelf Simply providing data, models, and analytical results on a CD or DVD can help, but creative solutions to the problem are needed The use of hypertext is promising in that it would allow a person reading a brief summary of the risk assessment to bore into a topic to the depth that is appropriate to interests and needs However, creating a large hypertext document is not quick or easy, and many people not like to read from a computer screen 35.2 COMMUNICATING ECOLOGICAL RISKS Risk communication is the process of conveying the results of risk assessments to decision makers, stakeholders, or the public, and of receiving and responding to their comments (Some documents define risk communication to include consultation during planning and problem formulation.) It goes beyond the issue of reporting the results of the risk assessment in a clear and useful manner to actually conveying the results to a skeptical audience It is difficult for two reasons First, like any quantitative and scientific subject, it is difficult to convey to those who not have the requisite training or experience Risk assessments may be particularly difficult to explain, because they combine biological and physical sciences with mathematics and statistics Second, situations that require risk assessments are often emotionally charged People’s health, livelihood, and property values are typically at stake, and distrust is typically high Most of the literature of risk communication is directed at issues of managing emotions and gaining trust with respect to health risks, independent of the nature or quality of the technical message (NRC 1989; Fisher et al 1995; Lundgren and McMakin 1998) Those issues will not be treated here, because emotional investment in ecological issues is usually lower and is likely to be qualitatively different In many if not most ecological risk assessment cases with high levels of emotional investment, such as restrictions on harvesting, water withdrawals, or land use to protect resource species or endangered species, the issues are largely economic and the strong emotions are largely held by those who generate the risk Fishermen, loggers, ranchers, and farmers are reluctant to believe that their activities damage the environment in ways that would justify restriction of their activities Research is needed to guide risk communication in such situations The technical communication problems are more severe for ecological risk assessors than for health risk assessors Ecological risk assessors not only deal with unfamiliar scientific and mathematical concepts, but also often estimate risks to unfamiliar entities and attributes Decision makers and stakeholders know full well what a human is and have both knowledge of, and empathy for, the various fates that befall humans However, many will not know what a spectacled eider or an Atlantic white cedar bog is, much less the implications of changes in their nesting success or in hydro-period Humans have a sense of their own inherent value and their value to their family and community, but have little knowledge or appreciation of equivalent values of ecological entities Hence, much of ecological risk communication is a matter of education This education may require a little honest salesmanship as well as the basic description of an entity and attribute This may involve the use of attractive photographs and explanations of values associated with the endpoint Failure to protect the ß 2006 by Taylor & Francis Group, LLC environment should not occur because the decision makers lack a vivid understanding of what may be lost or gained A related communication problem is the greater familiarity of most decision makers with the relatively simple methods and results of human health risk assessments The numerous endpoints and multiple types of evidence employed in ecological risk assessments make them seem complex and ambiguous This problem may be alleviated as health risk assessments begin to use multiple lines of evidence and to estimate the range of public health outcomes However, in the meantime, decision makers tend to focus on aspects of ecological risk assessment that seem familiar As a result of that tendency and the natural affinity of people for mammals and birds, risks expressed in the familiar terms of effects on survival or reproduction of such species tend to be inordinately influential For other endpoints, it is important to explain not only what they are and how they respond but also why they are assessed using unfamiliar methods and models As far as possible, use analogies to health risk assessment For example, analyses of biological survey data in risk assessments can be described as ecological epidemiology, and species sensitivity distributions can be described as dose–response models for ecological communities Finally, the unfamiliarity of ecological methods and models often leads decision makers to ask whether they are official methods or have been used previously in decision making Therefore, it is important to be prepared to cite guidance and precedents If a genuinely novel method or model is used, be prepared to compare its results to those of more familiar methods or models and to explain the advantages of the innovation A more pervasive problem is the inherent difficulty of conveying scientific and mathematical concepts to people who are not trained in those fields As Cromer (1993) explains, science is difficult to and to convey, because it constitutes uncommon sense It has been suggested that this is because the human mind evolved to extrapolate directly from experience, which works routinely but results in flawed logic in complex or unfamiliar inferences (Pinker 1997; Dawes 2001) Further, even when reasoning carefully, the mind deals more easily with some sorts of information and problems than others (Pinker 1997; Anderson 1998, 2001) From these generalizations, some advice can be derived Avoid probabilities: People, including scientifically trained experts, have difficulty with probabilities, but understand and manipulate frequencies relatively easily (Gigerenzer and Hoffrage 1995; Gigerenzer 2002) Whenever possible without distorting the results, translate probabilities to frequencies when communicating risks This has the ancillary advantage of forcing you to determine exactly what you mean by a probability (Chapter 5) Use discrete units: Although most properties of nature are continuous, the mind divides the continua of time and space into events and objects For example, Bunnell and Huggard (1999) reduced the spatial continuum of forests to a hierarchy of units (patches, stands, landscapes, and regions), which could be more easily described to forest managers than sets or areas of forest Use categories: We not only discretize continuous variables, but also lump the units into like categories to which we assign names Hence, ‘‘folk biology is essentialistic’’ (Pinker 1997) Long after ecology has revealed the variance in species composition over space, we continue to name vegetation and ecosystem types (e.g., mixed mesophytic forest) Similarly, it is often easier to communicate the frequencies of categories (e.g., high, moderate, or low) associated with ranges of a continuous variable (e.g., flow) than to communicate the meaning of the variable’s probability density Use few categories: People tend to divide entities or events into only two or three categories such as drought, normal, and flood for flow regimes Tell stories: Information imbedded in a narrative is more convincing and remembered longer Every conceptual model is a potential story ß 2006 by Taylor & Francis Group, LLC Use multiple modes: Individual audience members will respond differently to verbal, diagrammatic, pictorial, or other modes of representation By using multiple modes of presentation you are more likely to achieve comprehension with one In particular, photographs of the effects being discussed such as photos comparing plants grown in site and reference soils or depictions of the diversity of fish species in a disturbed and reference stream can make unfamiliar effects vivid In addition, repetition increases comprehension and retention and repetition using multiple modes avoids boredom Similarly, in presentations it is advantageous to include speakers with different styles to engage the diverse members of the audience Use case studies: Even if your assessment is generic (e.g., national risks from mercury in coal combustion emissions), illustrate it with a particular case (e.g., loons in the boundary waters) People are more willing to extrapolate from one real case to many than from an abstraction to any real case Simplify carefully: Scientific concepts can be complex and difficult It is often advantageous to use a simple analogy to convey a complex system However, it is important to prepare qualifiers (e.g., of course it is not really that simple), because knowledgeable members of the audience, particularly those who are opponents, will pounce on an ‘‘oversimplification’’ (Schneider 2002) Remember the human analogy: While you are talking about risks to otters from eating fish, many in the audience will be thinking about what it implies for people eating fish Be prepared for the questions that such analogies imply and avoid statements that would alarm those who are focused on the human analogy or that contradict the human health risk assessment Avoid personalizing: Although personalizing a situation makes the message more vivid (e.g., ‘‘I would not let my daughter eat fish from that river’’), it is a bad strategy for risk assessors Present the results of your analysis and let the risk managers and stakeholders infer the personal implications Of course, this advice is superceded by the advice to know your audience For example, former US EPA administrator Ruckleshaus (1984) preferred that risk assessment results be presented as cumulative distribution functions, contradicting some of the previous advice This example also serves to remind assessors not to talk down to risk managers, stakeholders, or the public An individual who is not an environmental scientist and does not know what Bayesian means or what a Pimephales promelas is should not be treated as unintelligent A condescending or contemptuous attitude will be detected and will result in dismissal of your message On the contrary, people can understand and appreciate descriptions of complex natural systems if they are well presented The renowned conservation biologist Daniel Janzen has said of ecological complexity: ‘‘Audiences soak it up I was told that it’s too complicated and a lot of people won’t understand it Bullshit They understand it perfectly well’’ (Allen 2001) Risk communication is an opportunity to ensure that your efforts some good The audience is less likely to be hostile than in human health risk communication Because ecological risks are not personal threats, audiences are open to learning a bit about nature and how plants and animals interact with contamination or disturbance You have an opportunity not only to explain your results but also to educate and even entertain In that way, you can help to create a constituency for good ecological management ß 2006 by Taylor & Francis Group, LLC 36 Decision Making and Ecological Risks It is not industry, development or the nation’s growing population that poses the greatest threat to the environment, it is shortcomings in the political process that perpetuate environmental degradation Howard R Ernst (2003) In the conventional environmental and ecological risk assessment frameworks, risk assessors communicate their results to risk managers and then leave the room Decision making is viewed as a policy-based and science-informed political process that is best left to those who have political authority This description is accurate in many cases However, to clarify technical issues and avoid misunderstanding, risk assessors may be, and should be, involved in the decision-making process In some cases, distinct analyses are performed after the risk assessment and before the decision by economists or experts on decision analysis In such cases, risk assessors are likely to be involved in supporting or helping to perform those analyses In addition, even when risk assessors are not involved, they should have some understanding of the decision-making process so that their results may be as useful as possible and to avoid unrealistic expectations about their ability to determine the outcome The bases for decision making discussed in this chapter are limited to those that are riskrelated As discussed in Chapter 2, some environmental decisions are made based on best available technology or some other criterion that does not include risk It must be borne in mind that politics is the ultimate criterion Any of the decision criteria discussed below may be overridden by political ideology or political expediency 36.1 PREVENTING EXCEEDENCE OF STANDARDS The simplest and least ambiguous decision criterion is that if an environmental standard is violated, action must be taken To the extent that standards are based on ecological risks (Chapter 29), these are risk-based decisions 36.2 PREVENTING ADVERSE EFFECTS The national policy of the Netherlands states that exposure to substances should not result in adverse effects on humans or ecosystems (VROM 1994) Similarly, the US Clean Water Act prohibits ‘‘impairment of the physical, chemical, or biological integrity of the Nation’s waters.’’ Such policies provide the most clearly risk-based criteria for decision making Given a definition of adverse effects, one can determine whether they are expected to occur or whether the probability of occurrence is excessive, and that is sufficient grounds for action ß 2006 by Taylor & Francis Group, LLC 36.3 MINIMIZING RISKS Comparative risk assessments (Chapter 33) provide a basis for decision makers to choose the action that presents the least risk to human health or the environment Comparative risk estimates can be based on a technical risk characterization as discussed in Chapter 33 Alternatively, it can be viewed more broadly as a type of policy analysis that includes relative risks and psychosocial preferences concerning different types of risks in a process of stakeholder consensus building That approach can be thought of as a microscale application to a specific decision of the macroscale process of using comparative risk assessment for priority setting (Section 1.3.1) (Andrews et al 2004) 36.4 ASSURING ENVIRONMENTAL BENEFITS Often, either explicitly or implicitly, actions to protect the environment are judged to be defensible if they are expected to result in adequate benefits to the environment Benefits are the complement of adverse effects and their risks In the context of risk assessment, benefits are avoidance of a risk of adverse effects In the context of remediation and restoration, risks are the probabilities that benefits will not be realized or that damage will occur due to poor planning or execution, or chance events Benefits may be judged in terms of absolute benefits of an action, relative benefits of alternative actions (Section 33.1.5), or benefits relative to costs (Section 36.6) Concerns for the benefits of actions may be expressed when a program has been ongoing for some time, costs have begun to mount, and questions arise about the cost-effectiveness of the expenditures An example is the expenditure of $580 million on 38 projects to remediate contaminated sediments in the Laurentian Great Lakes without a clear linkage to increases in beneficial uses (Zarull et al 1999) At some point, faith in such large expenditures fails without evidence of benefits As a result, the Great Lakes Water Quality Board recommended the development of better methods to quantify the relationship between sediment contamination and use impairments, and to monitor the ecological benefits and beneficial uses of remediated sites 36.5 MAXIMIZING COST-EFFECTIVENESS Cost effectiveness analysis identifies the relative monetary costs of different means of achieving a standard, an acceptable risk level, or other goal The decision maker could then choose the least-cost method A variant of this idea that has had important environmental implications in the United States is the principles and guidelines framework of the Army Corps of Engineers which maximizes the net national economic benefits of project alternatives, as long as they not cause significant environmental degradation (USACE 1983) 36.6 BALANCING COSTS AND BENEFITS Cost–benefit analysis is increasingly applied to environmental regulatory and remedial actions The decision model is that the public benefits of regulations should exceed the costs of compliance to the regulated parties In some cases, it is sufficient to show that monetary and nonmonetary benefits qualitatively balance the costs However, strict interpretations of cost– benefit requirements allow only monetary benefits As discussed in Section 38.3, this requirement to monetize the benefits of ecological entities and processes can be a serious impediment to environmental protection ß 2006 by Taylor & Francis Group, LLC 37 Integration of Human Health Risk Assessment People are the problem, but any solution which does not serve people will fail Marty Matlock (unpublished presentation) Inevitably, when both human health and the environment are threatened by a common hazard, human health concerns dominate assessment and decision-making processes Ecological risk assessors can use the concern for human health to their advantage by using wildlife as sentinels for health effects, by integrating the ecological assessment with the health assessment so as to combine resources, and by showing how ecological effects influence human health and welfare 37.1 WILDLIFE AS SENTINELS Wildlife may serve as sentinels, thereby strengthening the case for current or future risks to humans (NRC 1991; Burkhart and Gardner 1997; Peter 1998; Sheffield et al 1998; van der Schalie et al 1999; Colborn and Thayer 2000; Fox 2001) An example of wildlife as sentinels is the observation of thyroid pathology in wildlife due to halogenated organic chemicals that led to studies in humans (Fox 2001; Karmaus 2001) However, most reports of the use of animal sentinels of health effects have not provided the types and levels of evidence needed before health decisions can be based on sentinel responses (Rabinowitz et al 2005) Although there are difficulties in extrapolating from wildlife to humans (Stahl 1997), they are conceptually no more severe than those associated with extrapolating from laboratory rats to humans Wildlife species are likely to be effective sentinels if they have a common source and route of exposure with humans but are more exposed, more sensitive, or more readily monitored They are, in general, likely to be more exposed and therefore likely to respond more quickly and severely than humans (Box 2.1) In general, the use of wildlife as sentinels may be justified by the following factors: Common routes: Wildlife may feed on the same organisms as humans, particularly in the case of piscivorous wildlife and subsistence or recreational fishermen Similarly, wildlife may consume contaminated soil, as children Stenophagy: Wildlife species are generally less omnivorous than humans and therefore species that consume a contaminated food item are likely to be more exposed Local exposure: Wildlife species not obtain food or water from outside their home range, so they are more exposed to contaminated locations Same mixture: Wildlife species are exposed to the same mixture of contaminants as humans living in, or consuming foods from, the same contaminated system ß 2006 by Taylor & Francis Group, LLC Nonenvironmental sources: Wildlife species not have the occupational or lifestyle exposures that confound epidemiological studies of humans Variance: Most human populations are genetically diverse due to immigration and vary in their diets, religious practices, occupations, use of recreational and medicinal drugs, etc These sources of variance, which not occur in wildlife, tend to hide effects of environmental exposures Availability: Wildlife may be readily sampled, analyzed, and necropsied While wildlife are more commonly sentinels for humans, in some cases humans may be sentinels for wildlife Birth, death, and disease records, which may be used to detect environmental effects in humans, are not available for wildlife In addition, in some cases, humans may be exposed and affected where equivalent wildlife are rare or absent (Fox 2001) As a result, a field termed conservation medicine or conservation health has developed to jointly study effects on human and nonhuman organisms of environmental pollutants and pathogens (Weinhold 2003) This approach may result in the development of integrated sentinels For example, harbor seals have been proposed as sentinels for other marine mammals and humans (Ross 2000) A database of studies from the biomedical literature of the use of animal surrogates can be found at http:==www.canarydatabase.org 37.2 INTEGRATED ANALYSIS OF HUMAN AND ECOLOGICAL RISKS For practical reasons, the methodologies for human health and ecological risk assessment were developed independently However, for several reasons, the need for a more integrated practice of risk assessment has become clear These issues led the World Health Organization to develop an integrated framework for health and ecological risk assessment (Section 3.2.1) (WHO 2001; Suter et al 2003) 37.2.1 COHERENT EXPRESSION OF ASSESSMENT RESULTS Decision makers must make a single decision with respect to an environmental hazard that is beneficial to both human health and the environment, but this goal is impeded by the presentation of incoherent results of health and ecological risk assessments The results of independent health and ecological risk assessments may be inconsistent and the bases for the inconsistency may be unclear because the results of the health and ecological risk assessments are based on different spatial and temporal scales, different degrees of conservatism, or different assumptions, such as assumed parameter values or assumed land use scenarios As a result, decision makers may find it difficult to decide whether, for example, the reported risks to humans are sufficient to justify taking a remedial action that will destroy an ecosystem As another example, consider a decision to license a new pesticide that poses an increased risk to humans and a decreased risk to aquatic communities relative to a current pesticide If the ecological risk estimates are based on expected effects on a spatially distributed community while the health risks are based on provision of a margin of safety on an effect level for a hypothetical maximally exposed individual, the two estimates of risk cannot be compared Finally, if variance and uncertainty are not estimated and expressed equivalently for health and ecological risks, a decision maker cannot determine the relative need for additional research to support future assessments For example, variance in aqueous dilution should be either included or excluded in both assessments, and, if it is included, the same estimates should be used Integration of health and ecological assessments can avoid these impediments to defensible decisions ß 2006 by Taylor & Francis Group, LLC An integrated comparative risk assessment of contaminated sediment management illustrates this issue (Driscoll et al 2002) The assessment used a common set of alternatives and assumptions in a common health and ecological risk assessment that highlighted common results (the no-action alternative had the highest risk for both endpoints) and differences (island disposal had the highest ecological risk of the remedial alternatives but had relatively low health risk) 37.2.2 INTERDEPENDENCE Ecological and human health risks are interdependent (Lubchenco 1998; Wilson 1998b) Humans depend on nature for food, water purification, hydrologic regulation, and other products and services, which are diminished by the effects of toxic chemicals or other disturbances In addition, ecological injuries may result in increased human exposures to contaminants or other stressors For example, addition of nutrients to aquatic ecosystems and the resulting changes in algal community structure may influence the occurrence of waterborne diseases such as cholera as well as toxic algae such as red tides The need to assess ecological risks in order to estimate indirect effects on human health is particularly apparent in the assessment of climate change (Bernard and Ebi 2001) 37.2.3 QUALITY The scientific quality of assessments is improved through sharing of information and techniques between assessment scientists in different fields For example, in assessments of contaminated sites, human health assessors may use default uptake factors to estimate plant uptake, unaware that ecological assessors are measuring contaminant concentrations in plants from the site The data sets available for the safety evaluation of chemicals in human food and drinking water are relatively large and are used to support intensive assessments In contrast, ecological risk assessments for chemicals have relatively small data sets and few resources to perform assessments, even though the receptors include thousands of species such as plants, invertebrates, and vertebrates Integration of efforts may help to alleviate these imbalances in quality 37.2.4 EFFICIENCY Integration of human health and ecological risk assessments offers significant increases in efficiency In fact, isolated assessments are inherently incomplete when both humans and ecological systems are potentially at risk For example, the processes of contaminant release, transport, and transformation are common to all receptors Although only humans shower in water and only aquatic organisms respire water, the processes that introduce the contaminants to water, degrade or transform them, and partition them among phases are common to both Therefore, there are clear advantages in an integrated exposure model The development of risk assessment methods, which takes into account insights from both human and ecological risk assessments, will lead to improvements that can benefit both disciplines Integrated analysis of toxic risks will be facilitated by the increasingly mechanistic character of toxicology Because the structure and function of vertebrate cells are highly conserved, the mechanism of action of a chemical is likely to be the same in all vertebrate species and even the effective concentration at the site of action is likely to be effectively constant (Section 23.1.6) (Escher and Hermens 2002) Hence, when toxicology is sufficiently mechanistic, the need for toxicity testing should decline, and a common effects analysis approach should serve for both humans and other vertebrates However, this approach would increase the demand for toxicokinetic modeling to estimate site of action concentrations ß 2006 by Taylor & Francis Group, LLC 37.3 ENVIRONMENTAL CONDITION AND HUMAN WELFARE One view of risk assessment and management is that we protect human health as well as the nonhuman environment, and the only connection between them is through environmentally mediated or transmitted threats to human health (Section 37.2.2) An alternative view is that we must consider not just human health but also human welfare, and that human welfare is influenced by environmental conditions Environmental quality influences human welfare through the provision of ecosystem services Humans obtain a wide range of benefits from the environment, often termed services of nature, which make human life possible and enhance its quality (Daily et al 1997, 2002) At the most basic level, plants capture the energy of the sun, produce food for humans and their livestock, and convert our CO2 into O2 Other life support functions of ecosystems include purification of water, air, and soil, and cycling of water and nutrients In addition, ecosystems produce a variety of goods, such as timber, fisheries, biomass fuels, and medicinal herbs, roots, and spices These services are estimated to be worth more than the entire monetary economy (Costanza et al 1997; Naeem et al 1999) The concept of restoring services is already contained in the Natural Resource Damage Assessment provisions of some US laws (Section 1.3.9) A more subtle aspect of this issue is improvement in the quality of human life provided by nature (Keach 1998) An obvious example is the regenerative effect of a vacation spent fishing, hunting, bird-watching, hiking, photographing nature, or simply visiting natural places However, day-to-day contact with nature such as walking in parks, feeding birds, and observing trees, flowers, and butterflies may be more important to the quality of life The importance of this relationship to people’s quality of life is reflected in various behavioral and economic measures including the billions spent on feeding birds and the value of houses on large lots in the outer suburbs or on bodies of water The inverse of this relationship is the consternation people feel when they observe trees dying along highways, dead fish along a river, or even images of oiled birds on the television Finally, cultural values are often related to aspects of the environment This is particularly true of indigenous peoples whose cultures require the use of certain natural resources and the presence of certain environmental features (Harris and Harper 2000) The same is true of nonindigenous cultures, although in less obvious ways Examples from the United States include the bald eagle as a national emblem and unspoiled wide-open spaces as a backdrop for the national mythos of cowboys and hearty pioneers Forests have played a similar role in German culture (Schama 1995) It is important to distinguish risks to nonhuman organisms, populations, and communities from risks to human welfare through loss of ecosystem services Most environmental legislation protects ecological entities irrespective of any requirement to demonstrate benefits to human welfare (EPA 2003c) However, when they can be demonstrated, risks to human welfare could significantly supplement ecological and health risks as justifications for environmental protection At least, they provide a basis for estimating economic benefits of protective actions (Section 38.2) 37.4 SUMMARY To become more influential in environmental decision making, ecological risk assessors must collaborate with, and supplement, health risk assessors The performance of risk assessments for reductions in human welfare and indirect effects on human health is a large task that cannot be readily performed by ecological risk assessors Health risk assessors must be encouraged to look beyond direct toxic effects to a broader view of risks to humans Integration will require movement from both directions ß 2006 by Taylor & Francis Group, LLC 38 Integration of Risk, Law, Ethics, Economics, and Preferences To derive conclusions about action, we need some statements about how the world works and some statements about what we believe are good and right Randall (2006) Risks are never the sole basis for decision making (Chapter 36) Risks are more acceptable when there are countervailing benefits, and actions to reduce risks are more acceptable if there is a clear legal mandate, legal precedent, or public support Increasingly, formal analyses of costs and benefits are required Therefore, integration of the risk assessment with the economic analysis should be planned during the problem formulation However, it is also important to be aware of the limitations of economic decision criteria and of the existence of other decision criteria Environmental law, environmental economics, and environmental ethics are large and complex fields in their own rights, which are barely touched on here This chapter is intended to simply create an awareness among ecological risk assessors of these other considerations so that they have an idea of how their risk estimates must be combined with these considerations during the decision-making process 38.1 ECOLOGICAL RISK AND LAW Risk assessment may contribute to both criminal and civil law It may be used to demonstrate compliance with environmental laws or failure to comply It may also be a tool to establish injuries in civil legal actions The language of the law lends itself to concepts of risk: ‘‘more likely than not,’’ ‘‘the preponderance of evidence,’’ or ‘‘beyond a reasonable doubt.’’ When laws provide clear and specific legal mandates, legal compliance is a sufficient justification for action For example, the US Endangered Species Act provides clear legal protection for species that are listed as threatened or endangered and for their critical habitat Efforts to restore the bald eagle and peregrine falcon were not subject to cost–benefit analyses or public surveys Other laws such as the US Clean Water Act not include economic considerations in its mandate to restore the ‘‘physical, chemical, and biological integrity of the Nation’s waters,’’ but the interpretation of these vague terms leaves room for balancing of interests in defining criteria and standards However, once legal standards are established, risk assessment may simply estimate the probability that the standard will be exceeded Other phrases in laws such as ‘‘reasonably achievable’’ create a mandate for balancing the environment against economic costs Hence, the legal context of an assessment determines the degree of confidence required for an action and the extent to which risks must be balanced against other considerations ß 2006 by Taylor & Francis Group, LLC 38.2 ECOLOGICAL RISK AND ECONOMICS In the United States and many other nations, efforts to improve environmental quality and protect nonhuman populations and ecosystems are increasingly subject to cost–benefit tests This practice is based on welfare economics, which is based on the premise that when resources are limited, the general welfare is best achieved if individuals are free to maximize their individual welfare (also termed utility) through free markets for goods and services In an ideal market, the decisions of rational individuals (including corporations as legal individuals) will lead to an efficient outcome This invisible hand of the market often fails, particularly with respect to the environment The main reason for these market failures is the absence of a market for environmental goods such as clean air or wild songbirds Similarly, the services of nature such as water purification and soil formation are performed without anyone receiving a utility bill from nature Polluters may destroy these goods and services without buying the right in an efficient market, replacing the lost goods and services, or compensating the users Finally, for commonly held resources such as fisheries, there is an incentive for overexploitation The economic gain goes to the irresponsible individual, but the resource loss is shared by all, leading to ‘‘the tragedy of the commons’’ (Hardin 1968) Regulation is needed to compensate for these market failures To ensure that regulation is not excessive, welfare economists devised the cost–benefit analysis, which creates a pseudo market Costs of regulation are assumed to be justified if they buy an equivalent benefit of environmental goods and services An obvious difficulty in this concept, even for welfare economists, is that environmental benefits are difficult to define and enumerate, much less quantify in monetary terms Alternative approaches to estimating monetary benefits of environmental protection are listed in Table 38.1 All have severe limitations The revealed preference methods require that the value of a resource be quantified in terms of some monetary expenditure to use the resource, such as using the cost to recreationists of visiting an ecosystem as an estimate of the value of the ecosystem Clearly, such methods address a small fraction of the value of nature Stated preference methods, particularly contingent valuation, are more commonly used to value the environment, because they use surveys to create an entirely hypothetical market In particular, contingent valuation is used to estimate the monetary damages that polluters must pay to replace lost ecosystem services under Natural Resource Damage Assessment (Kopp and Smith 1993) These survey-based methods may be applied to any use or nonuse value, but they suffer from a number of problems including: The public has little understanding of most environmental resources and services Even if they understand the resource or service, they may not have relevant well-defined values to be elicited by a survey Even if respondents have well-defined values, the values may not encompass the full utility of the resource or service Any attempt to educate the survey participants is likely to bias their responses The respondents have no experience in pricing or paying for valued ecological resources or services It is not known whether respondents would actually pay the stated amount if a market could be created The number of resources or services that can be addressed is limited by the patience of the survey participants People may not be willing to pay anything, because they believe the responsible party should pay People may opt out because they object to putting a price on nature ß 2006 by Taylor & Francis Group, LLC TABLE 38.1 Methods for Estimating Monetary Values of Environmental Goods and Services Method Description Examples Revealed preference methods (can estimate use values only) When environmental goods are traded in The benefits of an oil spill cleanup that markets, their value can be estimated would result in restoration of a from transactions commercial fishery can be projected from changes in markets for fish, before and after the spill, and their effects on fishermen and consumers If an improvement in air quality would Production function The value of an environmental good or lead to healthier crops, the value of the service can be estimated when it is improvement includes, e.g., the needed to produce a market good reduction in fertilizer costs to produce the same amount of agricultural crops Hedonic price method The value of environmental characteristics If an improvement in air quality improves a regional housing market, its value can be indirectly estimated from the includes increases in housing value, market, when market goods are affected which can be measured by statistically by the characteristics estimating the relationship between house prices and air quality The value of a recreational fishing site to Travel cost method The value of recreational sites can be those who use it can be estimated by estimated by examining travel costs and surveying visitors, to determine the time relationship between the number of visits and the costs of time and travel Stated preference methods (can estimate both use and nonuse values) In a telephone survey, respondents are Contingent valuation Individuals are surveyed regarding their directly asked their willingness to pay, method willingness to pay for a specifically via a hypothetical tax increase, for a described nonmarket good project that would reduce runoff, improving the health of a particular stream In a mail survey, hypothetical alternative Conjoint analysis Survey respondents evaluate alternative recreational fishing sites are described descriptions of goods as a function of by type of fish, expected catch rate, their characteristics, so the expected crowding and round-trip characteristics can be valued distance; respondents’ preferences are used to calculate value for changes in each of the characteristics Market Source: Bruins, R.J.F., Heberling, M.T., eds., Integrating Ecological Risk Assessment and Economic Analysis in Watersheds: A Conceptual Approach and Three Case Studies, EPA=600=R-03=140R, Environmental Protection Agency, Cincinnati, OH, 2004 These problems can introduce significant biases as well as uncertainty For example, the last two problems described in the list cause people who are strongly pro-environment to opt out, thereby biasing the sample If one of these cost–benefit techniques is applied to an environmental decision, it is incumbent on ecological risk assessors to support that analysis If a revealed preference ß 2006 by Taylor & Francis Group, LLC method is used, the assessment endpoints must be identified and quantified in terms of the good or service that is provided For example, if the market value of fish is used by the economists, reductions in harvestable mass of fish should be estimated If a stated preference method is used, endpoints must be defined that are potentially understood and valued by the public This may require converting a primary effect such as death of ugly forest lepidopteran larvae into valued secondary effects such as reduced abundance of beautiful birds, moths, and butterflies To ecologists, assigning monetary values to the natural environment is likely to be somewhat repugnant, and the techniques employed often seem scientifically suspect However, in a decision context that requires cost–benefit analysis, nonparticipation of ecological risk assessors is likely to result in minimizing or even ignoring environmental benefits other than improved human health This requires a different approach to risk assessment and decision making than the purely legal approach It is not enough to establish that no unacceptable effects will occur Rather, one must be able to estimate the risks of specific effects and the benefits of avoiding or remediating those risks When working in an economic decision context, it is important to engage the economists in the problem formulation process and to understand their needs and methods (Bruins and Heberling 2004) An extensive summary of environmental economics can be found in van den Bergh (1999), a review of economics for watershed ecological risk assessment is provided by Bruins and Heberling (2005), and relevant guidance from a US regulatory perspective can be found in National Center for Environmental Economics (2000) and Science Policy Council (2002) Analysis of economic and other benefits of ecological risk reduction can lead to a broadening of the scope of assessments For example, the restoration of riparian vegetation in agricultural areas is justified under the Clean Water Act in terms of improved water quality However, riparian communities have other benefits such as provision of habitat for birds (Deschenes et al 2003) While the problem formulation for a risk assessment focuses on the endpoints that relate to the legal mandate, the accounting of benefits to justify the cost of riparian restoration is not constrained in that way Just as all of the costs of requiring waste treatment, remediation, or restoration are identified and summed, so too should all of the benefits be identified and summed, not just those that were endpoints for the assessment In fact, it is hard to know where to stop The protection of an ecosystem results in a nearly infinite list of benefits All of the species have value, all of the functions have value, and every visible or audible detail of an ecosystem has at least some esthetic value The fact that the costs of regulation are relatively easily and completely tabulated (e.g., the costs of building and operating a waste treatment plant), while the benefits to human health and the environment are incompletely identified and estimated, has led to the idea that what is really practiced is ‘‘complete cost–incomplete benefits analysis’’ (Ackerman 2003) In fact, the costs to industry are routinely overestimated, largely because regulation leads to development of lower cost treatment technologies or waste minimization and reuse (Ruth Ruttenberg and Associates 2004) In the face of highly uncertain benefits, it may be desirable to abandon cost–benefit analysis in favor of an insurance-based approach For example, if the benefits of a policy such as greenhouse gas control are highly uncertain, a risk management approach can justify the cost of some control to avoid the risk of catastrophic losses This approach is equivalent to the precautionary principle, but is based on economic rather than ethical principles A failure of contingent valuation and the other techniques in Table 38.1 is that they treat people strictly as consumers People are also citizens who contribute to the formation of laws as discussed in Section 38.1 (Sagoff 1988) A person as a purely self-interested economic entity may be willing to pay very little to protect streams in other states, but that same person as a citizen of a democracy may agree that the political process should protect streams nationally, leading to legal criteria and standards In addition, welfare economics ignores the fact that ß 2006 by Taylor & Francis Group, LLC people are ethical and act in ways that are rational but not maximize their economic welfare 38.3 ECOLOGICAL RISK AND ETHICS Welfare economics is not the only intellectual system for supporting environmental protection Formal ethics may be applied The fundamental difference between considering the environment in an ethical manner rather than an economic manner, no matter how broad, is illustrated by Routley’s last man argument (Schmidtz and Willott 2002) Consider that you are the last person left in the world and you have little time to live If you decided that it would be fun to cut down the last surviving redwoods, would there be anything wrong with that? Resource value, services of nature, and even esthetics would be irrelevant Yet, I hope that most readers would agree that the act would be wrong What would make it wrong is some ethical principle While the public has been responsive to appeals for environmental protection that are effectively ethical, ethics has had little influence as a formal decision support tool relative to law or economics This is in part because there is no generally accepted system of ethics analogous to classic welfare economics Ethicists have no standard classification system, but ethical principles and systems generally fall in the following categories: Motivist: The acceptability of an act depends on the intent of the individual This is the basis of the distinction between murder and manslaughter and for the requirement of ‘‘intent to deceive’’ in financial fraud It has little relevance to modern environmental ethics, but may have been important in traditional cultures that allowed use and even waste of resources if it was done with the proper intent as displayed by rituals and incantations (Krech 1999) Consequentialist: The acceptability of an act depends on its effects This is the basis for utilitarian ethics and its offspring, welfare economics However, consequentialist and even utilitarian interests may extend well beyond economic welfare People may be willing to give up economic resources out of sympathy for nonhuman organisms or in order to avoid repugnant experiences Deontological: The acceptability of an act depends on its nature This concept of ethics is related to concepts of duty, obligation, and rights It is associated with Kant, but its bestknown expression in the environmental literature is Aldo Leopold’s land ethic, which expresses a human obligation to protect the land, by which he meant ecosystems Those who ascribe moral standing to nonhuman organisms, populations or ecosystems are taking a deontological stance Environmental ethics are well summarized in Blamey and Comon (1999), and the range of positions in environmental ethics is represented in Schmidtz and Willott (2002) The implications for risk assessment of ethical standards are less clear than those for legal or economic standards Deontological ethics would tend to promote protective standards rather than the balancing of interests suggested by consequentialist ethics However, some consideration of consequences is nearly inevitable For example, if we have a duty to both aquatic and terrestrial ecosystems, the decision to sacrifice a terrestrial ecosystem for sewage sludge disposal must be based on a determination that the consequences of not generating the sludge or of disposing of it in the ocean would be more severe or at least less acceptable Also, since different versions of the concept of duty toward the environment are conflicting, consequentialist ethics may be required to decide between them For example, animal rights advocates condemn Leopold’s land ethic because it implies management of animals for the sake of ecosystems Therefore, a decision to protect an ecosystem by harvesting herbivores ß 2006 by Taylor & Francis Group, LLC that are not naturally controlled would be based on a judgment about the consequences of not harvesting 38.4 ECOLOGICAL RISK, STAKEHOLDER PREFERENCES, AND PUBLIC OPINION Traditions and public opinions inform politics, which in turn drives the legal process and influences how individual management decisions are made In addition, stakeholders may be involved in decision making as well as participating in planning and problem formulation This trend has been encouraged in recent publications of advisory panels on risk assessment (National Research Council 1994; The Presidential=Congressional Commission on Risk Assessment and Risk Management 1997) This advice is based on concerns that decisions that are not accepted by the affected parties will be politically unacceptable and may be blocked or delayed While these processes are usually informal, decision analytic methods that utilize multiple utilities can make this process as rigorous as cost–benefit analysis without requiring the conversion of preferences to monetary units (Brauers 2003) From an ecological perspective, increasing stakeholder influence is unfortunate in that it tends to accentuate human health concerns and diminish ecological issues The responsible parties not push for ecological protection, the members of the public who are sufficiently motivated to participate are primarily those with health concerns, and environmental advocacy groups tend to adopt the public’s health concerns or are simply absent The stakeholders who care passionately about ecological issues tend to be those who use or harvest natural resources (e.g., loggers, ranchers, fishermen, farmers) and therefore are opposed to protection Hence, in most stakeholder processes, nobody speaks for the trees Ecological risk assessors who participate in stakeholder-informed decision processes should be prepared to make the case for the environment by clearly presenting the results of their assessments in a way that the stakeholders can relate to (Section 34.2) If a management decision is of sufficient importance, national surveys of public opinion may serve to balance the interests of stakeholders An example is the current conflict in the United States over oil development in the Arctic National Wildlife Refuges Such ecological issues of national importance, for which environmental advocacy organizations can mobilize public opinion, are rare In routine assessments, risk managers who are public officials must represent the public’s interests, based on law and policy 38.5 CONCLUSIONS Most of this book has been concerned with how to estimate risks in an accurate and unbiased manner, addressing the endpoints of concern at the right spatial and temporal scales, and presenting results clearly and appropriately The critical final step is ensuring that the results are influential in the full context of the decision This chapter has described other considerations that may influence the interpretation of ecological risks Ecological risk assessors who simply drop their results on the risk manager’s desk are almost guaranteed to be frustrated by how little their work is reflected in the decision Ecological risk assessors must learn to work with lawyers, economists, policy analysts, and others who have the ear of risk managers For most of us, introverted ecologists who prefer dealing with the complexities of nature than with the complexities of human emotions or institutions, this is more of a challenge than calculating integrals of exposure and effects distributions ß 2006 by Taylor & Francis Group, LLC 39 Monitoring the Results of Risk Management Many impacts cannot be foreseen and planning must therefore provide for monitoring and adaptation Holling (1978) Results of ecological risk assessments are uncertain and regulatory and remedial actions may have unexpected effects Therefore, risk-based decisions are not guaranteed to have the desired outcome Environmental monitoring can reveal the actual outcome and guide further assessments, decisions, and actions Unfortunately, the effects of environmental management actions on ecosystems are seldom monitored Rather, it is typically assumed that the problem is resolved, and assessors and managers move on to the next problem This is ostensibly a reasonable approach Managers choose actions that they believe will be efficacious, and it seems reasonable to assume, at least, that unassessed and unremediated sites are worse However, the efficacy of remediation and restoration techniques is often uncertain, they may be poorly carried out, and, in any case, the law of unintended consequences applies A fundamental question to be answered by monitoring is whether exposure and effects have been reduced by a remedial action? While it might seem self-evident that treatment of effluents or removal of contaminated media would reduce exposures, studies not always bear that out In particular, dredging of polychlorinated biphenyl (PCB)-contaminated sediments has not, in some cases, reduced exposure as measured by accumulation in bivalve molluscs and fish (Rice and White 1987; Voie et al 2002) In effect, the mass of material decreased but availability to the biota did not Further, remediation may reduce exposure but not eliminate toxicity Following dredging and capping of the Lauritzen Channel of San Francisco Bay, California, concentrations of chlorinated pesticides declined in sediment and decreased in transplanted mussels at one site but increased at another (Anderson et al 2000) One year after remediation, the benthic invertebrate community contained few species and individuals, and the sediment was more toxic to amphipods than prior to remediation The registration of new pesticides and new industrial chemicals lends itself to post-management monitoring and assessment This practice is particularly common for pesticides In the United States surveillance studies are sometimes required of the manufacturer Because applications are replicate treatments, such studies are relatively easy to design In fact, the availability of this option was a reason that requirements for preregistration field testing of pesticides have been largely eliminated in the United States (Tuart and Maciorowski 1997) Because effluent permitting based on concentrations of individual chemicals does not account for combined toxic effects, effluent toxicity testing (Section 24.4) was developed as a means of monitoring the success of effluent permits However, because effluent tests are periodic, they are likely to miss episodes of high toxicity due to treatment failures, temporary ß 2006 by Taylor & Francis Group, LLC Riv er Water treatment plant Upstream dilution water for biomonitor Treated wastewater (effluent) Industrial site Untreated wastewater (influent) Wastewater treatment plant 3 Surface water biomonitor or upstream biomonitor for a water treatment plant Water treatment plant biomonitor Influent wastewater biomonitor Effluent wastewater biomonitor FIGURE 39.1 Diagram of a system to biologically monitor the toxicity of waste water (From van der Schalie, W.H., Gardner, H.S., Bantle, J.A., De Rosa, C.T., Finch, R.A., Reif, J.S., Reuter, R.H., et al., Environ Health Persp., 107, 309–315, 1989 With permission.) changes in a process, or other incidents Continuous biological monitoring of treated effluents has been proposed, but has not yet been adopted (Figure 39.1) Effluent permitting may also fail to protect the environment because of the combined effects of multiple effluents and of nonpoint sources In the United States, biological monitoring and bioassessment programs by the states and tribes are intended to detect those combined effects and provide a basis for regulating total pollutant loading, i.e., total maximum daily loads (TMDL findings) (Houck 2002) The primary limitation on this ecoepidemiological approach (Chapter 4) is the high cost of performing adequate monitoring at enough points at sufficient frequencies for the many water bodies of a state or nation The results of removing an exotic species should be monitored, because removal does not necessarily resolve ecological problems For example, removal of livestock from Santa Cruz Island, California, and from one of the Mariana Islands resulted, in each case, in explosive growth of a formerly uncommon exotic weed and suppression of native plants (Simberloff 2003) Hence, monitoring is necessary to assure that ecosystem management goals are achieved as well as to confirm that the species has been removed Similarly, ecological restoration projects are often physically but not ecologically successful In particular, wetland restoration projects often succeed in creating a wetland but fail to establish diverse wetland communities that support target species such as clapper rails or that adequately perform wetland functions such as nutrient retention When designing post-management monitoring programs, it is important to carefully consider the goals The first goal will be to determine whether the endpoint attributes that prompted the management action were restored For example, the assessment of the Lauritzen Channel remediation monitored changes in contamination of sediment and mussels, in ß 2006 by Taylor & Francis Group, LLC toxicity to invertebrates, and in invertebrate community structure, but could not answer the question of efficacy because the endpoint assemblage, benthic fish, was not monitored (Anderson et al 2000) The second common goal is to determine the cause of any management failure, which requires that the contaminant levels and other intermediate causal parameters be monitored along with the endpoints This can be difficult, because failure often occurs due to some process that assessors did not consider For example, the Lauritzen Channel assessment did not include possible sources of sediment contamination other than the United Heckathorn Superfund site (Anderson et al 2000) Therefore, it is important to develop conceptual models of alternative candidate causes and identify variables that distinguish them and could be monitored Media toxicity tests (Section 24.5) can play an important role in monitoring to determine efficacy By testing treated or remediated media, it is possible to distinguish ongoing effects that are due to residual toxicity from effects of other causes Such tests can even precede remediation, if treated media are available from pilot-scale studies For example, solvent extraction of soils contaminated primarily with PCBs removed 99% of the PCBs, but the toxicity of the soil to earthworms and plants was unchanged or even increased, depending on the species and test endpoint (Meier et al 1997) If monitoring reveals that the ecological system is not recovering or is still impaired after sufficient time has been allowed for recovery, an ecoepidemiological study should be conducted to determine the cause (Chapter 4) Residual impairment may be due to failure of the remedial action to sufficiently reduce exposure to the agent of concern or to the effects of other hazardous agents This analysis requires that the residual impairment be clearly defined, that plausible candidate causes be listed, and that analyses be performed based on spatial and temporal associations of candidate causes with the impairment, experimental results, and mechanistic understanding Successful causal analysis requires that the candidate causes and the residual impairment be monitored concurrently at the impaired site and at reference sites so that spatial and temporal associations can be determined Once the most likely cause has been determined, an ecological risk assessment of the new remedial alternatives can inform a decision concerning appropriate management actions Another goal of monitoring management results is to improve understanding of what assessment practices are successful and to determine how and why other assessment practices fail, so that the practice of ecological risk assessment can advance It is also valuable to determine whether failures tend to be overprotective or underprotective There is evidence for both For example, studies of toxic effects on striped bass embryos contaminated from maternal PCB burdens led the EPA Region II (2000) to conclude that effects on striped bass populations were likely in the Hudson River However, a careful analysis of long-term striped bass population data showed no effect of PCBs on year-class strength, apparently due to density-dependent compensatory processes (Barnthouse et al 2003) In contrast, continuous monitoring of Prince William Sound has shown long-term ecological effects that were not predicted by assessments performed shortly after the Exxon Valdez spill (Peterson et al 2003) In particular, short-term toxicity studies of the water-soluble fraction of the oil—thought to be the toxicologically active fraction—resulted in predictions of no significant risk to fish However, exposures of salmon eggs to persistent 3- to 5-ring hydrocarbons in field sediments and in the laboratory caused increased mortality for years after the spill Hence, limitations in the state of the science and the need to employ simplifying assumptions in ecological risk assessments have caused errors in both directions In sum, monitoring of the results of management actions is essential to ensuring that the goals of those actions are achieved In addition, real progress in ecological risk assessment depends on the feedback provided by well-designed and conducted monitoring programs Neglected areas of environmental chemistry and toxicology such as the toxicology of reptiles ß 2006 by Taylor & Francis Group, LLC will remain neglected until they are shown to be important in real-world decisions Similarly, relatively neglected assessment techniques such as population and ecosystem simulation modeling are likely to remain neglected until it is demonstrated that management decisions have failed and would have succeeded if those techniques had been employed ß 2006 by Taylor & Francis Group, LLC ... 35.1 REPORTING ECOLOGICAL RISKS The form in which ecological risks are reported is an oft-neglected aspect of the practice of ecological risk assessment The EPA’s guidance for risk characterization... assessment compare with past assessments Source: Adapted from EPA (U.S.Environmental Protection Agency), Guidelines for Ecological Risk Assessment, EPA =63 0=R-95=002F, Risk Assessment Forum, Washington,... environmental and ecological risk assessment frameworks, risk assessors communicate their results to risk managers and then leave the room Decision making is viewed as a policy-based and science-informed