Since there is no risk-free world and resources are limited, society
must set priorities based on cost-effectiveness in order to save the most
lives. 77 The EPA projected in 1991 that the cost to society of environmental
regulations in 1997 would be about $140 billion per year (about 2.6 percent
of gross national product). 78 Most of this cost is to the private sector.
Several economic analyses have concluded that current expenditures are not
cost-effective; that is, resources are not being utilized so as to save
the most lives per dollar. One estimate is that the U.S. could prevent 60,000
deaths per year by redirecting the same dollar resources to more cost-effective
programs. 79 For example, the median toxin control program costs 146 times
more per year of life saved than the median medical intervention. 80 This
difference is likely to be greater, because cancer risk estimates for toxin
control programs are worst-case, hypothetical estimates, and the true risks
at low dose are often likely to be zero. 81 [See Misconception #6.] Some
economists have argued that costly regulations intended to save lives may
actually lead to increased deaths, 82 in part because they divert resources
from important health risks and in part because higher incomes are associated
with lower mortality. 83 Rules on air and water pollution are necessary (e.g.,
it was a public health advance to phase lead out of gasoline) and clearly,
cancer prevention is not the only reason for regulations. However, worst-case
assumptions in risk assessment represent a policy decision, not a scientific
one, and they confuse attempts to allocate money effectively for risk abatement.
Regulatory efforts to reduce low-level human exposures to synthetic chemicals
because they are rodent carcinogens are expensive because they aim to eliminate
minuscule concentrations that now can be measured with improved techniques.
These efforts are distractions from the major task of improving public health
through increasing scientific understanding about how to prevent cancer
(e.g., the role of diet), increasing public understanding of how lifestyle
influences health and improving our ability to help individuals alter lifestyle.
Why has the government focused on minor hypothetical risks at huge cost?
A recent article in The Economist84 had a fairly harsh judgment:
"Predictions of ecological doom, including recent ones have such a
terrible track record that people should take them with pinches of salt
instead of lapping them up with relish. For reasons of their own, pressure
groups, journalists and fameseekers will no doubt continue to peddle ecological
catastrophes at an undiminishing speed.... Environmentalists are quick to
accuse their opponents in business of having vested interests. But their
own incomes, their fame and their very existence can depend on supporting
the most alarming versions of every environmental scare. 'The whole
aim of practical politics' said H.L. Mencken, 'is to keep the
populace alarmed - and hence clamorous to be led to safety - by menacing
it with a series of hobgoblins, all of them imaginary.' Mencken's forecast,
at least, appears to have been correct."
Dr. Aaron Wildavsky discusses worst-case risk assessment in his book
But Is It True: A Citizen's Guide to Environmental Health and Safety
Issues.85 "We should be guided by the probability and extent of
harm, not by its mere possibility. The search for possibilities is endless
and it trivializes the subject. There is bound to be great diversion of
resources without reducing substantial sources of harm. Consternation is
created but health is not enhanced.... Weak causes are likely to have weak
effects. Our search should be for strong causes with palpable effects, like
cigarette smoking. They are easier to find and their effects are much more
important to control.... The past necessity of proving harm has been replaced
by a reversal of causality: now the individuals and businesses must prove
that they will do no harm. My objection to this...is profound: our liberties
are curbed and our health is harmed."
Acknowledgments. This paper is modified from testimony March 6,
1997 for the U.S. Senate Hearing on Environmental Risk Factors for Cancer
and FASEB J. Vol. 11, 1997. This work was supported by the National Cancer
Institute Outstanding Investigator Grant CA39910 to B.N.A., the Director,
Office of Energy Research, Office of Health and Environmental Research of
the U.S. Department of Energy under Contract DE-AC03-76SF00098 to L.S.G.,
and the National Institute of Environmental Health Sciences Center Grant
ESO1896.
NOTE: Nothing written here should be construed as necessarily reflecting
the views of the National Center for Policy Analysis or as an attempt to
aid or hinder the passage of any bill before Congress.