A report is presented on a study of the influence of a number of conceptsand attitudes on the ways in which administrators use environmentalhealth standards. The survey covered federal, state, and local agencies.Findings are presented -and discussed.

THE USE OF STANDARDS IN THE ADMINISTRATION OF

ENVIRONMENTAL POLLUTION CONTROL PROGRAMS

Morris A. Shiffman, Ph.D., F.A.P.H.A.

THE significance of environmental pol-lution control standards has changed

from their beginnings as simple ruleswith limited effects on society to theirpresent status as complex functions withmultiple effects on major segments ofsociety. The complexities involve mat-ters of scientific fact, but the perplexi-ties are those which involve questions ofsocial and economic costs and of pub-lic policy. Standards have been definedas quantitative criteria for social and ad-ministrative policy making, whose pur-pose is to guide or restrain individualor group behavior with an assumed bene-fit to society as a whole.1 The particularfocus of this study is not to deal with thestandard as a technical tool, but ratherto explore the use of the standard bythe program administrator. The surveyis therefore a systematic attempt torecord and analyze bureaucratic be-havior. A recent report2 on pollutioncontrol emphasizes this approach bynoting that, "The issue with respect tostandards lies not so much in the con-cept or use of standards as such, but inhow and to what purpose they are used."The questions that relate to adminis-

trative behavior in the use of standards,include:

1. The utility and dis-utility of standards inprogram planning, program operations, andregulatory activities.

2. The role of standards in decision-making.3. The administrator's perception of the de-

velopment of standards.4. Opinions on the validity of standards.5. The influence of these opinions on the

acceptance and utilization of standards by theadministrator.

6. The influence of professional societies onthe development and administration ofstandards.

7. The measure of the authority representedby the standard and the extent of the ad-ministrator's dependence on this authority.

8. Intergovernmental problems in the de-velopment and administration of standards,including the degree of acceptance of stand-ards promulgated at superior level of govern-ment and conflicting requirements of differentgovernmental standards.

9. Variations in the acceptance of standardsdepending on the source of the standard withingovemment or in the various professionalsocieties.

10. Variations in the utilization of standardsrelative to the degree of authoritarianismshown by the administrator.

These issues are easily recognizableto environmental health practitioners.Attitudes and opinions on the use ofstandards have been expressed widely.3A6There is an extensive literature whichdeals with concepts of administrative use

and misuse of standards, validity, ad-ministrative discretion and responsibil-ity, decision-making, and other signifi-cant factors in administrative be-havior.7"14 The concepts of standards asdescribed in this literature were com-

FEBRUARY, 1970 255

pared with the concepts and attitudes ofthe practitioners as expressed throughthe questionnaire study of administratorsof environmental control programs.

Methodology

The study was designed to measurethe influence of these concepts and atti-tudes of the administrator on the wayshe will use environmental health stand-ards. Attitudes are difficult to define andto measure, but are a vital element inreceptiveness to change and predisposi-tion to action. An attempt to make theadministrator's attitudes discernible aswell as to identify the source of theseattitudes is a necessity for the under-standing of decision-making. The ex-ploration of this dimension of manage-ment was approached through a nation-wide questionnaire survey of the rela-tively small group of environmentalhealth personnel who are responsiblefor the administration and direction ofenvironmental health programs, or forthe direction and supervision of special-ized components of an environmentalhealth program. These persons are as-sumed to be those who influence theconduct and performance of environ-mental control programs in public healthagencies. Their opinions, attitudes, andperceptions of standards determine themanner in which standards shall be ap-plied in program administration.The criteria for inclusion of persons

in the sampling plan are listed below. Allthe criteria relating to the type ofagency, occupation, and position levelhad to be satisfied for inclusion in thesampling plan.A. Persons responsible for the direction of

an environmental health program, or for amajor component of a program such as sanitaryengineering, environmental and food sanitation,industrial hygiene, radiological health, airpollution control. These are programs in whichstandards have a major role in policy de-velopment, administration, and technology.

B. Employment in a state health depart-

ment or a local health department serving aminimum population of 100,000 and located inan urban area and offering services in severalor all the programs specified above. The re-quired degree of comprehensive program cov-erage was usually reached in those agencieswhich served urban populations of 200,000 ormore. These larger agencies make up themajor portion of the sample population forlocal health agencies.

The federal government has taken anactive interest and leadership in the pro-motion of standards for environmentalcontrol, especially in the areas of waterpollution, air pollution, food protection,and radiological health. The sample fromfederal agencies is limited to personsactive in these areas.There are a few cases in which air

pollution control is in a division of stateor local government other than the healthdepartment, and an industrial hygieneprogram may be found in a state de-partment of labor and industry. Theagencies were then included in the sam-ple in these cases. The questionnaire wassent to 447 persons. There were 271 re-spondents, or 61 per cent of the totalmailing, who fully completed the ques-tionnaire. The breakdown in response bythe level of governmental agency was asfollows:

AgenciesStateFederalLocal

Questionnairesmailed17121255

447

Replies116 or 67.8%17 or 81.0%

138 or 54.1%

271

The 271 respondents who completedthe questionnaire gave their primaryprogram area specialty as environmen-tal health administration (110), sani-tary engineering (23), environmentaland food sanitation (51), industrial hy-giene (25), radiological health (29), airpollution control (26), and other (7).

It is necessary to identify those whodid not reply to the questionnaire andto learn the reason for this lack of re-sponse, insofar as this is possible. There

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ENVIRONMENTAL HEALTH STANDARDS

is the requirement for establishing thenature of the nonrespondents and de-termine if this was due to some basicdifference between respondents and non-respondents. This step was attemptedthrough the examination of (1) lettersreceived from persons who were mailedthe questionnaire explaining why theydid not return the questionnaire; (2)explanatory notes on questionnaireswhich were returned without being com-pleted; and (3) checking the completedquestionnaires for comments and multi-ple signatures or other evidence that thequestionnaire had been completed byseveral persons (as an agency consensus)rather than by an individual.The sampling plan required that sepa-

rate questionnaires be sent to individualsresponsible for separate program com-ponents in the same department as wellas to the director of the department. Inseveral cases, particularly in the statehealth departments, the director of theenvironmental health program respondedin the name of the whole agency andfor the separate staff members, althoughseparate questionnaires had been sent tothese staff members. For example, thefollowing statement is from a completedquestionnaire received from the directorof environmental health of a state healthdepartment:"These entries are a composite of the views

of the staff of the Division. A muiltiple num-ber of questionnaires were received addressedto various members of the staff, but only oneis being retuirned."

In summary. of the total mailing of447 questionnaires, complete question-naires were received from 271 re-spondents and other replies from an ad-ditional 31 persons. In all, replies werereceived from 302 persons or 68 per centof those who received the questionnaire.The following analysis of results repre-sent the data from those respondentswho returned complete questionnaires.The data was further analyzed for dif-ferences in response bv generalists and

specialists, for program specialty, andfor local, state, and federal agencies.The questionnaire was divided into

three sections:Section A-"General Considerations

on the Use and Effectiveness of Environ-mental Health Standards" containsthe questions which deal with the re-spondents' opinions and perceptions ofstandards as an integral concept with-out reference to a specific standard.These results are described in this re-port on the abstract general concept ofthe standard and the standards process.

There is, of course, a continuous feed-back between knowledge and experi-ence with a specific environmental healthstandard or standards, and the abstractview of the standards. This essentiallinkage is recognized in Sections B andC of the survey.

Section B - "Environmental HealthStandards in Current Use" deals withspecific environmental health standardswhich have wide application in publichealth practice.

Section C-"Proposed EnvironmentalHealth Standards" which have deter-mined a great deal of interest and someconflict. These include the proposedstandards on Ambient Air Quality Cri-teria, Radiological Health Standards forthe General Population, and Microbio-logical Standards for Foods.The organization of the survey into

these three sections makes possible com-parisons based on the linkages betweenthe abstract concept of the standardsprocess, the acquaintance with a specificstandard, and opinions on futurestandards. The results of these linkagesand of the data in Sections B and Care only briefly discussed in this report.

Results

A primary purpose of environmentalhealth standards is to provide a tool andyardstick for the program administrator.It is important to assess the adminis-

FEBRUARY, 1970 257

Table 1-Concepts of the usefulness of environmental health standards in programadministration

Administrative Very useful Useful Little use No response Totalprocess No. % No. % No. % No. % No. %

Program planning 96 35.4 140 51.7 28 10.3 7 2.6 271 100Measuring environmental

health problems 140 51.7 113 41.7 10 3.7 8 3.0 271 100Enforcement 149 55.0 93 34.3 23 8.5 6 2.2 271 100

Achieving uniformadministration 139 51.3 115 42.4 12 4.4 5 1.8 271 100

Public relations 83 30.6 133 49.1 49 18.1 6 2.2 271 100Program evaluation 93 34.3 127 46.9 43 15.9 8 3.0 271 100

trator's concept of the usefulness of thestandard in this respect (Table 1). Pro-gram administrators and specialists re-sponsible for environmental pollutioncontrol activities in governmental agen-cies attach a high degree of utility tothe use of environmental health stand-ards in program management. How-ever, there is a higher value attached tothe use of standards in the administra-tive processes of enforcement, achievinguniform administration, and measure-ment of technical problems than in thoselonger range administrative processeswhich include program evaluation, pro-gram planning, and the maintenance ofcommunity and legislative relations.Therefore, the respondent's concept ofthe utility of standards is as an aid inthe day-to-day operational phases of theprogram rather than with the planningand supportive aspects of the program.There are differences in response be-tween generalists and program specialistsin 'all these administrative processes ex-cept for planning. The specialist finds agreater utility for standards in the meas-urement of environmental health prob-lems, but less use for standards in en-forcement and achieving uniform admin-istration.A dominant theme in the literature of

the standards process has been a warn-

ing that dependence on standards bythe administrator stifles research and de-velopment, and fosters a rigidity of atti-tude to the detriment of the public andindustry. The need for flexibility instandards is stressed as well as the neces-sity for revision with time and techno-logical change. Standards have beencited as impeding the administrator inthe use of his best judgment and con-tributing to a tendency to abdicate re-sponsibility in the performance of hisfunctions. The program administratorsand specialists did recognize the possi-bility of environmental health standardsas impediments to effective programoperation and administration (Table 2).Almost 50 per cent of the respondentsdid consider that standards could bedeleterious to some extent in these re-spects; however, very few thought thatstandards were definitely defective forapplication in environmental health pro-grams. Over one-third of those replyingsaw no defect at all in the applicationof environmental health standards. Theresults indicate that the program admin-istrators and specialists are sensitive tothe possible administrative shortcomingsof environmental health standards. How-ever, very few think these are disablingand a large number do not perceive anyshortcomings. This result differs then

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Table 2-Concepts ofministration

the defects of environmental health standards in program ad-

Administrative Definitely Some None No response Totalobjection No. % No. % No. % No. % No. %

Loss of flexibility inprogram operation 16 5.9 131 48.3 120 44.3 4 1.5 271 100

Restricting the range ofdecision-making 26 9.6 136 50.2 103 38.0 6 2.2 271 100

Rigid standards leadingto unreasonablerequirements 39 14.4 132 48.7 91 33.6 9 3.3 271 100

Established standardsstifling newv approachesto problem solution 37 13.7 115 42.4 111 41.0 8 3.0 271 100

from the view in the literature whichemphasizes the presumed defects of en-vironmental health standards in pro-gram administration.

Another statement that appears in theliterature is that standards which areadopted officially and become an integralpart of a legal regulation or code be-come entrenched and difficult to reviseas needs change. The thought is thatadvisory standards are preferable be-cause of the facility in revising themand because advisory standards do notbecome riaidly- established. There is amarked preference among administratorsand specialists for the officially adoptedstandard (Table 3).The deleterious effects of these stand-

ards on the user have been expressed.Standards are supposed to diminish thejudgment and responsibility of the ad-ministrator and cause him to evade re-sponsibility through an overdependenceon a rigid numerical criterion. Fifty-seven per cent of those replying wouldthemselves reserve the prerogative togrant tolerances to the standard basedon their judgment of the situation. Thisrepresents an expression of administra-tive discretion. Thirty per cent of the re-spondents. however, were ready to ac-cept some limitation to the free exercise

of their administrative discretion. Thisresult may indicate a conflict betweenthe administrative role which empha-sizes regularization of procedures asagainst the professional value whichprizes the use of individual professionaljudgment. This conflict is related to thereal life situation in which the adminis-trator is caught between a public andlegislative demand for the rigid imple-mentation of standards and his profes-

Table 3-Preference for the use of officialor advisory standards

Preferencescale No. %

Advisory standardsmost preferable 32 11.8

78 28.8Advisory standards

preferable 46 17.0

Equal preference 69 25.5

Official standardspreferable 65 24.0

120 44.3Official standards

most preferable 55 20.3

No response 4 1.5

271 100.0

FEBRUARY, 1970 259

sional role which requires a judiciousdiscretion in the application of thestandard to the particular situation.

Need for Administrative Interpretation

The same element of conflict is seenin the answers to questions relating tothe need for administrative interpreta-tion of the standard (Table 4). Over 60per cent of the respondents disagreedwith a statement that standards shouldbe promulgated in such an exact anddefinite form that there is little needfor administrative interpretation. Thiswould represent the professional valueand is the point of view supported bymuch of the literature on the standardsprocess. The surprising feature in theseresponses, however, was the large groupof respondents (35%o) who agreed thatthere was little need for administrativeinterpretation in the implementation ofstandards. This latter view represents aparticularly rigid attitude in the applica-tion of standards.The validity of the standard is an

important concept in the standards proc-ess. The acceptance and use of the stand-ard may be influenced by the user's per-ception of its validity. In this study va-lidity was defined in terms of the ob-jective procedures for developing andpromulgating the standard, includingthe availability of published informationand criteria which are the basis for thestandard. The primary factor in theuser's acceptance of the standard was hisconfidence in the organization which wasthe source of the development of thestandard (Table 5) . The second factorchosen was the respondent's knowledgeof the professional reputation of thecommittee members who were chargedwith the development of the standards.There was some difference between gen-eralists and specialists in this respect.The generalists had a higher confidencein the organization source (68% vs.54%)o, while the specialists emphasizedthe professional reputation of the com-

mittee members (23% vs. 14%). Com-parison of these results with the litera-ture is also interesting. The standardsuser has a very high confidence in theexpert committee which develops thestandards (Table 6). On the other hand,members of the expert committees tendto be somewhat apologetic in their de-scription of the standards process, notingthe compromises, inadequacies, andjudgmental elements involved in the set-ting of a standard.The development of standards re-

quires a complex interrelationship andcooperative effort between members ofgovernmental agencies, professional so-cieties, and industry. Despite this co-ordinated effort, each standard bears theimprint or label of some government or-ganization, professional society, or otheridentifiable source. This primary sourcelabel identifies the standard in the mindof the user and influences his perception

Table 4-Concepts of administrative dis-cretion and responsibility in the useof environmental health standards

a. Standards shouild be promulgated in stich1an exact and definite forn that there islittle need for administratie interpretation

Agreement scale No. %

Definitely agreeTend to agreeDon't knowTend to disagreeDefinitely disagreeNo response

27 10.066 24.44 1.5

84 31.088 32.52 .7

271 100.0

b. Admninistrators uitilize environimental healthstandards to minimize their responsibilityfor making decisions

Definitely agreeTend to agreeDon't knowTend to disagreeDefinitely disagreeNo response

17 6.363 23.224 8.994 34.771 26.22 .7

271 100.0

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Table 5-Concepts of the bases for acceptance of atative

standard as authori-

First choice Second choiceBases for acceptance No. % No. %

Confidence in the organization wvhichis the primary source for thedevelopment of the standard 166 (100)* 61.3 52 (26) 19.2

(66)t (26)

Knowledge of the professionalreputation of individuals on thecommittee wvhich developedthe standard 49 (21) 18.1 92 (47) 33.9

(28) (45)Personal acquaintance 'with

individuals on the committee 6 (3) 2.2 11 (6) 4.1(3) (5)

Recognition of other organizationsrepresented on the committee 9 (2) 3.3 74 (47) 27.3

(7) (27)

Other factors 29 (15) 10.7 13 (7) 4.8(14) (6)

No response 12 (7) 4.4 29 (15) 10.7(5) (14)

Total 271 100.0 271 100.0

* Generalist.t Specialist.

of the utility and validity of the stand-ard. There also may be differing per-ceptions attached to a standard whichderives from a federal, state, or localsource. One of the areas of conflict inthe development of environmental pollu-tion control standards has been, in dif-ferent opinions, as to the most appro-priate role for federal, state, or localpromulgation for air quality standardsand water quality standards. An impor-tant point in the explanation of thestandards process is to delineate the roleand relative influence of the sourcewhich is the prime initiator of the stand-ard. The initiation and development ofa standard rest most significantly within

Table 6-Perceptions of the scientificvalidity of environmental health stand-ards developed by committees of recog-nized experts

Opinionon validity No. %

Mostly valid 132 48.7

Frequently valid 116 42.8

Occasionally valid 16 5.9

Rarely valid 0 0.0

Don't know 4 1.5

No response 3 1.1

271 100.0

FEBRUARY, 1970 261

Table 7-Comparison of the influence ofstandards developed by governmentalagencies and professional societies onprogram operations

Standards developed byGovernment Professional

Extent of agencies societiesinfluence No. % No. %

Very much 145 53.5 52 19.2Much 89 32.8 101 37.3Some 24 8.9 90 33.2Little 3 1.1 14 5.2None 0 0.0 2 0.7No response 10 3.7 12 4.4

Total 271 100.0 271 100.0

one group, be it a governmental agencyor a professional society. The next se-ries of questions was designed to testthe degree to which differences in thesource of the standard influenced theprogram administrator.

It may be assumed that almost all re-spondents are members of one or sev-eral professional societies. This assump-tion is supported by the fact that thenames of the respondents were derivedin part from professional directories ormembership lists. Furthermore, many ofthe respondents have attained a degreeof professional distinction and it is usualfor persons at this level of attainment tobe active in their professional societies.Therefore, it would expected that theirvalues and belief system would adheremost closely to those of the professionalsocieties. However, standards developedby governmental agencies rather than byprofessional societies were preferred(Table 7). The answers offer some in-sight into the integration of technicaland professional personnel into a bu-reaucratic organization. The scientist ortechnologist who is a member of a bu-reaucracy is subject to a dual social con-trol from his professional referencegroup and from the employing agency.

There is interest among sociologists15'6as to whether professionals derive theirsocial control and express their loyaltyto their professional commitments abovetheir organizational commitments. Theseresponses demonstrated that the special-ist was more likely to prefer the stand-ards of professional societies than wasthe generalist. However, both groupsshowed a definite choice for the stand-ard of the governmental agency overthe professional society standard.-

This line of inquiry was pursued fromseveral points of view. In each case,the overriding opinion was that thestandard derived from a governmentagency source was the more effective,the more useful in an operational sense,and best suited to the needs of the re-spondent than the standards derivedfrom a professional society source(Tables 8, 9). These results may indi-cate that the user's perceptions of stand-ards are as devices which serve his ad-ministrative needs and his values as amember of the bureaucracy rather thanthe professional value.The relative influence on program

operations of standards issued by fed-eral, state, and local governments wasexplored in the next series of questions.In appraising the relative merit of these

Table 8-Comparison of the relativeeffectiveness of standards issued bygovernmental agencies and professionalsocieties in program administration

Source of the standard No. %

Government most effective 43 15.9Government more effective 132 48.7Equal effectiveness 74 27.3Professional societymore effective 7 2.6

Professional societymost effective 2 .7

No response 13 4.8

Total 271 100.0

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Table 9-Comparison of the influence ofgovernment and professional societiesstandards as guides in the developmentof community standards

Influence of thesource of the standard No. %

Government most important 56 20.7Government more important 81 29.9Equal importance 93 34.3Professional societiesmore important 11 4.1

Professional societiesmost important 8 3.0

No response 22 8.1

Total 271 100.0

governmental sources, the respondentsfrom local agencies have a generally fa-vorable opinion of state standards asmeasured by the extent of need formodifying these standards for local use.The state standard was considered moreapplicable than the federal standard orthe professional standard for applicationat the local level (Table 10).

Stringency of the StandardAnother important variable is the

user's perception of the stringency of

the standard. Approximately two-thirdsof the respondents felt that federal orstate health department standards werestringent enough for local use (Table11). A small number (23.6% for statestandards and 14.4% for federal) feltthat these standards were not stringentenough. There is a significant differencein the responses of personnel in state andlocal health agencies. Three-quarters ofrespondents from state agencies thoughtthat both state and federal standardswere acceptable in this respect for localuse. The local health group agreed in-sofar as the acceptability of federalstandards; however, one-third of the lo-cal personnel thought that state healthstandards were lacking in stringency. Areason for this reply may be in the dif-ferent level of familiarity of local per-sonnel with the federal and state stand-ards. The local personnel may be morefamiliar with the use of state standardsand are more knowledgeable as to theiroperational characteristics in practice.One of the cautions in the literature

is that administrators use numerical cri-teria in a mechanistic manner, especiallyin enforcement proceedings. The re-spondents were asked at what point theywould initiate legal enforcement follow-ing the first violation, second violation,

Table 10-Opinions on the need for the modification ofstandards to suit the requirements for local health depart-ment use

Source of the standardFederal State Professional

Need for agencies agencies societiesmodification No. % No. % No. %

Extensive 10 3.7 8 3.0 24 8.9Some 178 65.7 125 46.1 171 63.1Little 54 19.9 99 36.5 46 17.0No change 12 4.4 21 7.7 7 2.6No response 17 6.3 18 6.6 23 8.5

Total 271 100.0 271 100.0 271 100.0

FEBRUARY, 1970 263

Table 11 Opinions on the strictness ofpublic health service and state healthdepartment standards in reference totheir application in the local com-munity

Source of the standardPublic StateHealth healthService department

Stringency No. % No. %

Not stringentenough 39 14.4 64 23.6

Acceptable 194 71.6 176 64.9Too stringent 13 4.8 2 .7No response 25 9.2 29 10.7

Total 271 100.0 271 100.0

repeated violations, or no enforcement atall based on violation of the standard.Only 6 per cent of the respondents wouldinitiate enforcement following the firstviolation. Half of the respondents wouldonly initiate enforcement following re-peated violations. These data show thatthere is no tendency by the practitionerto use standards in a mechanical wayand that enforcement should only followrepeated violations. It is interesting tonote that the specialists were more likelyto reject numerical criteria as a causefor legal enforcement. Ten per cent ofthe specialists indicated that there shouldbe no enforcement action based on theviolation of a standard, while only 3per cent of the generalists would takeextreme positions.As noted, another section of the ques-

tionnaire dealt with a group of specificenvironmental health standards in cur-rent use. These findings are not exploredin detail here; however, some points ofinterest are summarized. The utility ofthese standards in practice was givena high rating, especially for the applica-tion of these current standards in en-forcement and in the achievement ofuniform patterns of administration. Incommon with the administrators' gen-

264

eral concept of the use of standards,planning is given a lower degree of ac-ceptance. All three specific standardswere given high ratings insofar as theusers' opinion on their practicability inprogram operations.Over 90 per cent of the respondents

indicated that the Public Health Serv-ice Drinking Water Standards and thebacteriological standards of the Rec-ommended Milk Code were practical toadminister. Eighty-six per cent ofthose familiar with Industrial HygieneThreshold Limits felt these were prac-tical to administer.

Future Use of Standards

A section of the study dealt with thefuture use of standards to meet newproblems in environmental health. Thissection is intended to translate the re-spondents' general concepts and opinionson current standards into preferences forspecific attributes such as the source,format, and desirability for the develop-ment of ambient air quality control cri-teria, radiological health standards, andmicrobiological standards for foods. Therespondents expressed a high degree ofneed for such standards. This reinfqrcesthe conclusion that environmental healthpersonnel have a strong dependence onand attach a high value to the utilityof standards in program operation. Therespondents also attach a higher accept-ance of officially adopted standards overstandards adopted in the advisory form.It is interesting to note that though therewas a strong expressed need for theseproposed standards, there were reserva-tions as to the possibility of developingvalid standards for the control of thesepollution problems. This lesser confi-dence in the validity of these standardsas compared to current standards maystem from the conflict surrounding thedevelopment of some of these particularstandards. The lesser confidence in thevalidity of these standards did not affectthe practitioners' expression of need for

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ENVIRONMENTAL HEALTH STANDARDS

such a standard for program operations.It may be that the concept of validityis more important to the standards-setterand the expert than it is to the adminis-trator and program specialist. A de-creased perception of validity does notseem to impede the proposed operationaluse of the standard by the program ad-ministrator and specialist.

There was an overwhelming demandfor a governmental agency source forthese proposed standards rather than aprofessional society-with the federalgovernment as the most preferred sourcefollowed by the state, and with the localgovernment as the least preferred gov-ernmental source.A standard is not an isolated pro-

nouncement. Social forces are exertedto initiate the development of standards.The development process involves the in-terplay of technical, economic, legal, so-cial, and political factors. By a similartoken, standards once developed do notexist in the abstract. They are appliedin a real world by human beings. Thefocus on attitudes and behavior in theimplementation of standards in environ-mental pollution control programs is auseful approach to the exploration of theorigins of administrative behavior.

REFERENCES

1. Wolman, Abel. Concepts of Policy in theFormulation of So-Called Standards ofHealth and Safety. J. Am. Water WorksA. 52:1343, 1960.

2. National Academy of Sciences-NationalResearch Council. Waste Management andControl. Publ. No. 1400, Washington,D. C., 1966.

3. U. S. Congress, Joint Committee on

Atomic Energy. Hearings, Radiation Pro-tection Criteria and Standards: TheirBasis and Use, 86th Congress, 2nd Ses-sion, 1960.

4. Thomas, Harold A., Jr. The Animal Farm:A Mathematical Model for the Discussionof Social Standards for the Control of theEnvironment. Quart. J. Economics 77:144,1963.

5. Kneese, Allen V. Comments on HaroldThomas' Animal Farm. Prepared for pre-sentation before the joint meeting of theSubcommittee on Water Supply and WasteDisposal of the Committee on SanitaryEngineering and Environment, NAS-NRC,Washington (May 7), 1963 (mimeo.).

6. Goldsmith, J. R. Bases and Criteria forAir Quality Standards. J. Air PollutionControl A. 14:22, 1964.

7. Irish, D. D. Evolution of Our Concept ofStandards. Arch. Environmental Health10:546, 1955.

8. Shuval, Hillel I. The Uses and Misuses ofEnvironmental Health Standards. A.J.P.H.54:1319, 1964.

9. Levine, M. Facts and Fancies of BacterialIndices in Standards for Water and Foods.Food Technol. 15:29, 1961.

10. McKee, J. E., and Wolf, H. W. (eds.) .Water Quality Criteria (2nd ed.). Sacra-mento: California State Water QualityControl Board, 1963.

11. MacKenzie, V. G. Air Pollution Standards.Arch. Environmental Health 2:224, 1961.

12. McCord, C. P. Man and His Environment-A Conference Resume. Indust.' Med. &Surg. 30:354, 1961.

13. McGaughev, P. H. Folklore in WaterQuiality Standards. Civil Engineering(June), 1965.

14. Davis, Philip J. The Criterion Makers:Mathematics and Social Policy. Am.Scientist 50:254A, 1962.

15. Gouldner. Alvin W. Cosmopolitans andLocals. Administrative Science Quart. 2:281, 1957.

16. Blau, Peter M., and Scott, Richard W.Formal Organization, A Comparative Ap-proach. New York: Chandler Publishing,1962.

Dr. Shiffman is Professor of Environmental Health, Department of Environ-mental Sciences and Engineering, University of North Carolina School of PublicHealth, Chapel Hill, N. C. 27514

This paper was presented before a Joint Session of Conference of LocalEnvironmental Health Administrators, Conference of State Sanitary Engineers,National Association of Sanitarians, and the Engineering and Sanitation,Occupational Health, and Radiological Health Sections of the American PublicHealth Association at the Ninety-Sixth Annual Meeting in Detroit, Mich.,November 11, 1968.

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