Re: Commissioner Dicus speaks

["Thomas E. Potter" <pottert@erols.com>]

Commissioner Dicus makes four main points in her speech:



- -  Society is willing to accept familiar or freely chosen risks more

readily than those that are imposed upon them. 



- -  Public risk acceptance usually occurs as a result of an offsetting

public benefit to that risk.



- -  Society demands that the mentality of "science must prevail" be

changed to one of "science must make sense."



- -  The decision making process succeeds when public involvement is

engaged from the outset and continues to play an integral part

throughout the process.



Commissioner Dicus and the NRC may be relying too heavily on public

involvement to make the regulatory process successful.  Public

involvement is clearly important.  Public fears need to be considered

thoughtfully in regulatory decision making.  But public fears should not

drive regulatory decisions.  It would seem that, at least in some

situations, the NRC decision must reduce to choosing between sensitivity

to baseless public fears and intellectual honesty. NRC failure to decide

properly in such a situation would be grossly irresponsible.



NRC also does not seem to appreciate very well that its best attempts at

public involvement can only be partially successful.  The population

that stands to gain the benefits from some technological application, a

population typically seeking only some optimized improvement in its

life, is often large, diffuse, and difficult to draw into some public

involvement program.  It is left to the technology vendor to make the

case for benefits, and, of course, the value of his view is usually

greatly diminished because his judgment is considered to be tainted by

the prospect of particular benefits that he would gain.  On the other

hand, it is never difficult to find some suitable representatives of the

population that would bear the risk under consideration.  Consequently,

the public that winds up involved is invariably skewed.  Some allowance

for this should be made in consideration of input from public

involvement, but I am not aware of any efforts to do so.



Commissioner Dicus properly notes the importance of the public

developing a sense of the balance between risk associated with a new

technology and the benefit that might offset it.  Unfortunately, given

the regulatory framework, regulatory decisions almost always focus on

management of the risks, often in a highly fragmented way, and pretty

much ignore benefits.  There is often little opportunity for systematic

examination of benefits and risks of potentially competing technologies

in regulatory decision making.  Thus, our regulatory system is skewed

against the introduction of any new technologies that carry identifiable

risks.



The "familiar" risks that seem readily accepted today were all, not so

long ago, unfamiliar.  Many, such as electricity, were widely feared. 

However, there was very little public involvement in decisions related

to the imposition of these risks.  It might be argued that additional

public involvement might have saved us considerable grief by rejecting

technologies that have caused excessive harm.  But it is also arguable

that additional public involvement would have prevented adoption of

highly beneficial technologies.  Do we think we're better off or worse

off now than we were 100 years ago?  (Interesting thought experiments: 

(1) How would the NRC-style decision making process work if we were

beginning only now to consider chlorination (never mind fluoridation) of

drinking water?  Consider, in particular, the wisdom of placing large

inventories of chorine in the vicinity of thousands of large population

centers.  (2) There is noticeable and growing resistance to compulsory

vaccination.  Should we reconsider (with intense public involvement, of

course, and suitably limited participation of experts) compulsory

vaccination programs?



We need public involvement in regulatory decision making. However,

public involvement can properly be only a limited adjunct to, not a

replacement for, thoughtful and reasoned consideration by qualified and

responsible (in the broadest sense) representatives of the public.



Tom Potter

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