Risk Assessment is a License to Kill

007-License to Kill

“Risk Assessment” is Fraud. It  is actually a highly disguised political choice to commit deadly harm.

It actually answers the perverse question “How can I get away with all the environmental and human damage my project will cause?” – though it is never stated so clearly.

Those wanting to do big projects that cause real harm have to disguise it because public opinion strongly opposes serious harms to people and our environment.

A method that superficially appears scientifically credible is called “Risk Assessment.” This thousand word article will show you why Risk Assessment is rarely credible and what to insist upon instead.

Imagine for a moment you are a developer, a resources extractor, a polluter or a government agency (DREG) that wants to do a project that causes a lot of harm to our environment or to people.

The first thing you do is hire a Biostitute (an academic or professional committing fraud for money) to write a report for you with the secret contract requirement or understanding that the report says all your project’s risks are “acceptable.” Since you are paying them, Biostitutes would have to be pretty dumb to give you a report that admitted your project would cause serious harm. Who would ever hire them in the future ?

So Biostitute’s report always defends and justifies environmentally harmful activities by overflowing with meaningless pseudo-scientific bureaucratic doublespeak and jargon ornamented with often irrelevant meaningless mathematics all wrapped up in a laundry list of logical fallacies.

Judges rarely understand environmental assessments due to the lavish insider jargon, or complex statistical analyses, but generally are pressured to accept them as though they were reasonable and valid – even when they are outrageously bogus. (“Well, its got lots of pages and math in it, and it was written by an “expert” so it must be ok …”)

Most (if not all) risk assessments are based on selective information, arbitrary assumptions and enormous uncertainties. Risk Assessments often admit not calculating for the most vulnerable people or real threats to imperiled species.¹(O’Brien 2000)

For example, US-EPA has been fighting for years against admitting the numerous known different deadly harms of pesticides to endangered species. EPA has lost huge lawsuits and still fight against admitting the pesticide harm. They avoid discussing it, then when forced to analyze a harm, they disguise the harms as described above.

Who Decides for You?

A valid risk assessment is when you decide for yourself how much health or safety risk you are willing to accept, presumably in exchange for some benefit. For example: if you decide to make a parachute jump or buy life insurance you make that sort of decision. That’s a valid risk assessment.

An outrageously wrong “risk assessment” is when government or a corporation decides for you how much of your health risk they are willing to accept.

No democracy-based government has a Right to Kill You or even let you die negligently without Due Process. But that’s not what DREGs believe – because you are getting in the way of their profits – or job promotion.

An example of how wrong this can get is how in 2007, faceless bureaucrats in the US-EPA, US Dept. Agriculture, California Dept. Food and Agriculture and California Dept. Pesticide Regulation (CDFA) all approved the aerial spraying of secret, untested pesticides on the cities of Monterey Bay area including Pacific Grove, Santa Cruz, Monterey, Seaside, Marina and Carmel.

CDFA’s Steve Lyle: Hostile to Public Voting Down the Aerial Spraying of Pesticides

The California state bureaucrats arrogantly fought having the public decide they didn’t want to be sprayed. Even after 23 cities including San Francisco and Monterey officially opposed the spraying — CDFA spokesman Steve Lyle sneered publicly “You don’t get to vote.”

License to Kill

Because Risk Assessment explicitly authorizes activities which kill innocent people (“only one cancer (death) per million people”) it is disparagingly and accurately referred to as a “License to Kill.”

Agencies that do this all the time include the US-EPA (aka Environmental Protection by Autopsy) —

“Generally, EPA is concerned when cancer risk estimates exceed 1×10-6 or one-in-one million“ (US-EPA Reregistration Eligibility Decision for Thiophanate-Methyl)

the Food and Drug Admin(FDA), CDPR (California Pesticide Approvals), OEHHA (California Toxics Health Assessment).⁽¹⁾ US-EPA does this every time they approve the use of a pesticide. EPA actually decides that if a pesticide is calculated to not kill more than one person per million exposed to it – that is an “acceptable risk” to them.

What they hope you don’t figure out (they are trying to obscure) is that put another way, this means that the US-EPA is willing to have 1 person die for every million people exposed to an intentionally deadly chemical.

The number of Americans at risk of dying from industrial chemicals was not always so high. For a short while the risk number was 1 person per 100 million. That’s less, but still an outrageous concept.

“1 chance in 100 million of developing cancer was put forward as safe. This figure was adopted by the Food and Drug Administration in 1973, but amended to one in a million in 1977 (Kelly and Cardon 1994). This level of 10–6 has been seen as something of a gold standard ever since. The US Environmental Protection Agency (EPA) typically uses a target reference risk range of 10–4 to 10–6 for carcinogens in drinking water…”

Risk Assessment is inherently wrong, morally, ethically and sometimes even legally when Judges understand how it really works. Someday courts will soundly throw it out for good just as they have rejected Flat Earth arguments. Lets hope it is soon.

So what do we do instead?

Alternative Analysis is the genuine examination of many different methods of achieving the same goals and to avoid or minimize environmental damage.

For example, instead of using poisonous persistent pesticides to kill weeds in your sidewalk – you can use a steam-wand that only uses hot water.

Alternatives are often better in every respect than the original concept. Well not in every respect, they do typically reduce profits of toxin manufacturers.

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Notes:
1. CDFA’s website banner “CDFA Protects Your Environment” is flat out fraud.

Their more accurate mission is: “California Department of Food and Agriculture: 94 years protecting and promoting agriculture in the golden state” (However, somehow the last part was cut off : “No matter how deeply human health and our environment is harmed by agricultural pesticides and other chemicals.”)

References:
1. “Making Better Environmental Decisions,” Mary O’Brien, 2000

2. US-EPA Risk Standards: Cotruvo, J.A. (1988) “Drinking water standards and risk assessment.” Regulatory Toxicology and Pharmacology 8, 288–299

3. US-EPA Reregistration Eligibility Decision, Thiophanate-Methyl
“Generally, EPA is concerned when cancer risk estimates exceed 1×10-6 or one-in-one million”
http://www.epa.gov/oppsrrd1/REDs/tm_red.pdf

4. Alachlor Pesticide Reregistration “Acceptable risk is 1 x 10-6 , or lower.”

5. EPA’s Risk Assessment Process For Tolerance Reassessment, Staff Paper #44, 1999