Download - RETHINKING DISPERSANT RISK ASSESSMENT PROCESSES Meeting the Information Needs of the Public
RETHINKING DISPERSANT RISK ASSESSMENT PROCESSESMeeting the Information Needs of the Public
Gary OttMarie Benkinney
FEAR
“It was from the dispersants.”
YouTube - Care at WJMC following oil spill http://www.youtube.com/watch?v=cD5SddZjMY8&feature=BF&list=PL78ECFEBDDC3C1A83&index=5
Risk: Low to High
Outrage not solved by better explaining “the numbers.”
WORDS: “Doubt… Evil… Tradeoff”
“I am, personally, not there yet.”EPA Administrator’s testimony: at http://www.youtube.com/watch?
v=3HsF6Tk4xts&feature=related
REGULATORY FRAMEWORK
“(PRODUCT NAME) is on the U.S. Environmental Protection Agency’s NCP Product Schedule. This listing does NOT mean that EPA approves, recommends, licenses, certifies, or authorizes the use of (PRODUCT NAME) on an oil discharge. This listing means only that data have been submitted to EPA as required by subpart J of the National Contingency Plan, Sec. 300.915.”
Product Schedule Disclaimer
1. REGULATORY FRAMEWORK
• EPA Policies Treat Dispersants Differently• RRTs are Assigned the Risk Assessment Responsibility
FDA - Drugs - National Standards - Choices Made by Doctor/Patient
EPA - Pesticides - National Standards - Choices Made by State/Farmer
• Establish a National Risk Assessment Process
NIC & National Commission Recommendation
2. MANAGEMENT CONTROLS
• High Risk – Lots of Management Controls• Low Risk – Not so Much
– Burden to prove a negative– Can’t reach market
NRT & EPA Recommendation
3. ECOLOGICAL RISK ASSESSMENT
• Helpless at SpillsMechanical Limitations and Pixi Dust
• RRT / Trustees Dispersant Decision PlanningTrustees Support is not rewarded
• Headquarters Takes Over Decision Process
NIC Recommendation
1. REGULATORY FRAMEWORK
EPA Disclaimer
“(PRODUCT NAME) is on the U.S. Environmental Protection Agency’s NCP Product Schedule. This listing does NOT mean that EPA approves, recommends, licenses, certifies, or authorizes the use of (PRODUCT NAME) on an oil discharge. This listing means only that data have been submitted to EPA as required by subpart J of the National Contingency Plan, Sec. 300.915.”
CONCLUSIONS - Fear
Probability of change?
2. MANAGEMENT CONTROLS
EPA Disclaimer
“(PRODUCT NAME) is on the U.S. Environmental Protection Agency’s NCP Product Schedule. This listing does NOT mean that EPA approves, recommends, licenses, certifies, or authorizes the use of (PRODUCT NAME) on an oil discharge. This listing means only that data have been submitted to EPA as required by subpart J of the National Contingency Plan, Sec. 300.915.”
CONCLUSIONS - Fear
Probability of of matching risk levels with appropriate management controls?
3. ECOLOGICAL RISK ASSESSMENT
EPA Disclaimer
“(PRODUCT NAME) is on the U.S. Environmental Protection Agency’s NCP Product Schedule. This listing does NOT mean that EPA approves, recommends, licenses, certifies, or authorizes the use of (PRODUCT NAME) on an oil discharge. This listing means only that data have been submitted to EPA as required by subpart J of the National Contingency Plan, Sec. 300.915.”
CONCLUSIONS - Fear
Probability Trustees are not rewarded, potential for liability, blame?
TrusteePhotoHere
USES of FEAR - Victim
“What I’m scared about is the dispersment...” NBC’s Nightly News “BP Spill” Anniversary, April 18, 2011: Dean Blanchard interview at http://www.youtube.com/watch?v=PWYOKyOFEF4