Posted: May 30, 2004
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Article SummaryRisk isn’t dichotomous. It is always possible to take more or fewer precautions and end up with a higher or lower risk. Since such decisions are matters of judgment, this column argues, people should be allowed to make their own judgments. Of course in many situations some (minimum) precautions may need to be required, and some (excessive) precautions may need to be forbidden. But between required and forbidden is a fruitful space for voluntary precautions. The column focuses especially on three examples: supplied air for cleanup workers (should the employer ever leave it up to the worker?); boiling water that might be contaminated (should the authorities ever leave it up to consumers?); and testing beef cattle for mad cow disease (should the government ever leave it up to the slaughterhouses?).

Between Required and Forbidden:
The Value of Voluntary Precautions

Three times in the past week I have run into a risk communication problem where it seemed obvious to me that part of the answer was voluntary precautions. In each case the organization involved wasn’t interested.

The three examples are otherwise quite different; about the only thing they have in common is a deep commitment to the notion that a precaution is either needed (in which case you should require or at least urgently recommend it) or not needed (in which case you should forbid or at least massively discourage it). There seems to be no middle ground, no sense that the best attitude to adopt toward a precaution might sometimes be neutrality: “Do this if you want to.”

Case One:
Supplied Air for Cleanup Workers

The first case involved a huge cleanup of a former nuclear weapons site. My client, one of the cleanup contractors, was locked in controversy with some of its employees over the safety of vapors occasionally escaping from storage tanks filled with radioactive chemical wastes. (Interestingly, the employees were long accustomed to the risks of radioactivity; it was chemical odors that had led them to worry about their health.) Of course my client routinely required various levels of personal protective equipment (PPE) when its industrial hygienists had determined that there might be offgassing of health significance. But for the most part where PPE wasn’t required it was fervently discouraged. Apparently there was actually a long-standing policy that allowed employees to “step up” their level of PPE on their own initiative, from nothing to a dust mask to a respirator with a filter cartridge. But the policy wasn’t well known (even by managers, much less by the employees themselves) and wasn’t often invoked. And supplied air – the most onerous form of PPE – was never permitted except when it was required.

Of course there is a rationale for not allowing personal protective equipment in situations where it isn’t called for. Going to work with supplied air is like going to work with scuba gear – up to forty pounds of equipment on your back, the taste of rubber in your mouth. Apart from the cost and the reduced productivity, this poses health risks of its own, from back injuries to sunstroke.

Nonetheless, I urged my client to permit PPE, and even supplied air, wherever possible. And I urged my client to do so visibly and aggressively, conceding that employee-controlled PPE had previously been discouraged by management and crediting dissident employees with successfully agitating for the policy change.

For employees in good physical shape who have been checked out on the equipment, I argued, even supplied air is probably no greater threat to health than anxiety over the vapors ... not to mention the possibility that the vapors themselves might pose some risk after all. So employees who aren’t worried about the vapors and hate the discomfort of supplied air, I said, are probably better off without it (except in situations where there are good technical reasons to think the vapors might be hazardous). But employees who are worried about the vapors and don’t mind the discomfort are better off with it, even in situations where the technical risk is near zero. And everybody, I said, is better off with some control over his or her own safety and working conditions – and the tradeoff between the two. For many employees, the availability of optional PPE will itself be a reassurance; knowing they can ratchet up their level of protection at any time will make work on the tanks less worrisome. For others, a few weeks on supplied air, working shoulder-to-shoulder with employees without such uncomfortable equipment, will be an incentive to rethink the tradeoffs. And for a few, supplied air will be the long-term solution.

The company balked at offering supplied air, but it did find a powered air-purifying respirator it could offer an an alternative. And it publicized the PPE-on-demand policy much more aggressively (though without giving much credit to the dissidents). For a few months, there was a real voluntary self-protective niche between required and forbidden.

Then the company changed policies again: All tank work would be done on respirators with cartridges to filter out ammonia, the most commonly smelled vapor. And since there were no cartridges to filter out nitrous oxide, all tank work where nitrous oxide vapors were a possibility would be done on supplied air. The new policy would remain in effect until further research was completed on possible vapor risks.

The new policy – the new, new policy – was largely a response to a political brouhaha. (A company communications manager disagrees. He says it was “a logical next step that very much looks like a bowing to political pressure.”) After a few months of relative quiet under the voluntary PPE policy, some employees resumed their complaints that they smelled the vapors; aided by their union and by a national activist group, they continued to argue that the safety of the vapors for all employees could not be guaranteed. This is a valid claim, as indeed the claim of absence of total certainty is always valid. Though the content of the tanks has been characterized pretty thoroughly, there are still questions remaining, in theory, about what might happen when miscellaneous radioactive chemicals are stored together for decades, then disturbed. Vapor odors are certainly detectable from time to time. Most experts doubt the risk is serious. So do most employees, many of whom resent the new obligation to wear respirators or forced air – a resentment that is bound to grow as summer arrives. But the U.S. Department of Energy, which awards and revokes contracts for nuclear waste cleanups, is understandably bothered by claims of chemical vapor risk. It is unlikely to be as bothered by claims (better substantiated but inevitably far less media-worthy) of back injuries or sunstroke.

In an effort to reduce the political heat on DOE, the company’s top managers decided to impose mandatory PPE requirements not just when they thought the risk was real, but when they couldn’t absolutely prove it wasn’t. The important improvement for my client was that employees on respirators or forced air aren’t likely to smell any vapors. So they aren’t likely to register as many complaints suggesting that the vapors they smell might be hazardous.

I appreciate my client’s goal of reducing employee outrage. Even without political pressure on (and from) DOE, the fact that some employees were worried about vapor risks justified taking some action. Even though the company’s industrial hygienists were just short of certain that the vapor risks were tiny, it was a mistake to discourage employees from ratcheting up their level of personal protective equipment if they wanted to. But why require the equipment? What strikes me as notable is my client’s conviction that voluntary PPE wouldn’t do the job.

Case Two:
Waterborne Hazards and Boil Orders

A few days after the PPE consultation, I spoke at the first conference ever held on “Water Security Risk Communication” – in a nutshell, how to tell people that the reservoir might be poisoned by terrorists. Sponsored by the U.S. Environmental Protection Agency, the conference featured more than a dozen speakers, most of them talking about how they had coped with a specific water security threat or how they planned to cope with one if it ever arose.

A theme in many of the presentations was the need to be ready to tell the public what to do – usually one of two options: boil the water, or don’t drink the water at all. This was obvious to all concerned in situations where the threat was clear. If you know the water has been tampered with, and you know you weren’t in time to shut off the supply, and you know what the agent is, then you know what to tell people to do. Even if you’re not sure, if you have reason to believe ricin (for instance) may have been dumped into the water supply and reached people’s faucets, you know what to tell them to do. The problem comes when you’re pretty sure it’s just pollen or vandals with a little paint, or you’re pretty sure you isolated the problem before it got into the system. You’re pretty sure people’s drinking water is unaffected. But not absolutely sure. Do you tell people to boil the water anyway, just to be on the safe side? Or do you tell them the problem is under control and the water is safe? Or do you tell them nothing – and if someone notices technicians in moonsuits taking samples, say it was a drill?

Or – my option – do you tell them you’re pretty sure the water is okay (otherwise you’d be implementing your crisis plan) but something a little weird did happen this afternoon and you haven’t quite got to the bottom of it yet? Do you suggest matter-of-factly that people who are extra-cautious might want to boil their water or drink bottled water for a day or two until you’ve dotted the i’s and crossed the t’s?

In mid-conference I asked an EPA official who manages the agency’s water security risk communication program whether she was aware of any mention of voluntary precautions in any EPA guidance document or water utility plan for responding to possible terrorist attacks. She said no. You either tell people to take a precaution, she said, or you tell them not to, or you tell them nothing at all.

I realize that voluntary precautions have some disadvantages. They leave you looking a little wishy-washy, like you can’t decide if the risk is real or not. They open you up to charges of failure of leadership. And they pose special problems for people who cannot easily make and implement their own precautionary decisions. What about prisoners and hospital patients who aren’t free to boil their water? What about the poor who can’t afford bottled water?

But being decisive has disadvantages too, especially if you’re being more decisive than the situation justifies. Voluntary precautions are most appropriate when the situation is ambiguous – either because you’re not sure what happened (possible tampering with the water supply) or because you’re not sure what the risk is (gases escaping from the waste tanks). In other words, voluntary precautions are most appropriate when there is a case to be made for taking the precautions and a case to be made for not taking them. Suggesting voluntary precautions means acknowledging that the situation is in fact ambiguous in just this way. It means admitting uncertainty. It means sharing the dilemma with the public – telling people you’re frankly not sure how serious the risk is and whether or not it justifies the precautions. It means relinquishing control, and treating people like grownups. That’s all part of why it’s an option that is rarely considered, and one I think is worth considering.

Voluntary precautions do raise people’s anxiety for a while, as they cope with the reality that you’re not sure what they should do and they have to decide for themselves. But they have two good ways to reduce their anxiety – they can take your recommendation, if you have one; or they can follow their own judgment. Most people are hard-wired to be capable of coping with anxiety; the long-term problem is usually desensitization and apathy, a premature return to the status quo – not panic or unremitting fearfulness. People’s over-reaction to new risky situations tends to be short-term only, an “adjustment reaction” until they get used to the New Normal. It helps people manage their anxiety if you acknowledge that voluntary precautions can be frustrating and anxiety-provoking, that everyone (yourself included) wishes you knew for sure what to do. It’s also worth acknowledging that voluntary precautions are a policy change that’s likely to take some people aback at first, since everyone has become accustomed to the required-versus-forbidden paradigm.

Notice that the absence of voluntary precautions also raises people’s anxiety. Mandatory precautions (“Don’t drink the water!”) certainly send a this-is-dangerous signal. And when you decide to recommend no precautions at all (“No reason not to drink the water!”), you leave fearful people alone with their fears, with no emotional support and no concrete advice to carry them through the adjustment reaction phase. You also leave a clear field for activists and alarmists.

The only way not to get at least a temporary increase in anxiety in the face of a new risk is to keep the new risk secret (“it was just a drill”). Secrecy works ... until the secret leaks, as it usually does. Then you reap the whirlwind: devastated credibility, high levels of mistrust, and resulting high levels of fear.

Case Three:
Testing Beef Cattle for Mad Cow Disease

Cattle and beef experts at the U.S. Department of Agriculture will remember 2003-2004 as a bad patch – not just the year they had to deal with the risk of Mad Cow Disease (Bovine Spongiform Encephalopathy or BSE), but the year they faced endless criticism for being less than candid about that almost certainly tiny risk. (Some of the criticism came from me. See Misleading toward the Truth: The U.S. Department of Agriculture Mishandles Mad Cow Risk Communication, by Peter M. Sandman and Jody Lanard.)

One of the (many) grounds for criticism has been the USDA’s unwillingness to permit private companies to do their own BSE testing. A number of countries, most notably Japan, test all their cattle for BSE, and refuse to buy beef from untested animals. Wishing to regain the Japanese market, some U.S. producers and exporters want to test – which the USDA maintains is unnecessary. The controversy over whether this particular precaution is useful or silly hinges mostly on two questions: (1) Whether the USDA’s own sampling and surveillance program is sufficient to ensure that U.S. beef is BSE-free or “virtually BSE- free,” making it pointless to test every carcass; and (2) Whether we are confident that cows less than 30 months old can’t have BSE yet because the disease’s latency is longer than that, and confident that cows claimed to be less than 30 months old really are, making it pointless to test these younger cows at all.

Leave aside the merits of these two questions. Assume that the USDA is right that testing is scientifically pointless. It will nonetheless reassure Japanese consumers, and will therefore profit American producers. Why outlaw the testing? Because, the USDA says, it’s bad science to do pointless testing.

There are other rationales for the anti-testing position. The USDA claims to be worried about false positives – that is, a mistaken finding of BSE from the quick-and-dirty screening test private testers would use. But the solution there is obvious: Any cow brain sample that tests positive gets sent to the USDA for its gold-standard confirmatory test. The USDA also claims to be worried about false negatives – the possibility that people could be falsely reassured by a good test result. But this is a strange objection from a government agency that insists categorically that the U.S. meat supply is “absolutely safe.” Some critics, on the other hand, speculate that the USDA may actually be worried about a true positive – another certified U.S. mad cow to undermine faith in the food supply. Better not to know.

I believe the USDA’s main concern is none of the above. It is worried (and has sometimes said so) that the availability of beef from cows tested for BSE will put beef from untested cows at a disadvantage. There is obviously a market for BSE-tested beef cattle. It’s hard to tell whether that’s a niche market or a huge market, maybe even the whole market. Is it just the Japanese and a few other extra-fastidious customers who will demand BSE testing, or will you and I and McDonalds also insist on testing if testing becomes available? The major U.S. beef producers would rather not have the additional expense of testing. If tests are permitted, the market will determine whether or not these producers reluctantly decide to test too. By prohibiting the tests, the USDA is preventing the market from working its will, and thus protecting the market for untested beef. At least it is protecting the domestic market for untested beef; the Japanese simply refuse to buy U.S. beef period.

A strange thing for a Republican administration to do? Aren’t Republicans supposed to believe in free markets? I don’t want to get into the debate over the protection of big industries from upstart competition, or the strained relationship between economic conservatism and political campaign contributions. Governments often seem intent on making precautions either required or forbidden even when they don’t have a big industry to protect – and regardless of whether it’s a Republican or a Democratic administration at the helm.

Some More Examples

Years ago I had a client that manufactured latex gloves. Like all companies in the latex business, it was dealing with the growing awareness of latex allergies, which can be devastating to the victim. My client had evidence from peer-reviewed journals that its gloves were less allergenic than comparable gloves produced by its competitors. But the U.S. Food and Drug Administration refused to allow this information in my client’s advertisements and package inserts. Not that the FDA thought the data were inaccurate. (I can’t vouch for the data, but that wasn’t the FDA’s objection.) The problem was rooted in the fact that latex products are regulated for allergenicity by the FDA. The FDA argued, therefore, that any latex product that satisfied the regulations was by definition “safe” – and so no company should be allowed to claim that its products were safer than safe. This reasoning effectively turned a floor into a ceiling, dichotomizing precautions into those that were required (meeting the FDA standards) and those that were, if not forbidden, at least banned from the sales pitch.

I asked my client if the ban would be upheld if the company sued the FDA for the right to tell prospective customers it had created a less allergenic latex glove. My client responded that winning a lawsuit against a regulator over a fairly minor issue is a pyrrhic victory at best; the regulator has too many ways to get even.

In the years that followed, I came to believe that the lawsuit might well have failed anyway. In more recent years, for example, a controversy over bovine growth hormone (BGH), a bioengineered product fed to dairy cattle, led some dairy companies to take steps to ensure that their cows had no added BGH (the cows do make some of their own). Some state regulators balked at letting these companies put the “no added BGH” message on the milk carton, or wanted them to add long caveats disclaiming any possible health implications. The message was true, they conceded, but without the caveats it misleadingly implied that added BGH might be harmful, whereas the government position in the controversy was that added BGH is “safe.” Even though the cartons made no actual claim of risk reduction, the regulators were reluctant to permit dairies to provide information that would permit consumers to take precautions the regulators considered unnecessary. Dairies that continued trying to cater to the market for no-added-BGH milk were often sued by Monsanto (a producer of BGH) and legally “cowed” into dropping the labels. What I want to note is that, once again, those in charge have passed up the opportunity to make a precaution voluntary and let the people (the market) decide. Like the USDA, the EPA, the country’s water utilities, and my waste cleanup contractor client, the agencies regulating latex and milk seem intent on making sure precautions are either required or forbidden.

There are plenty of exceptions, often at the hands of the very same agencies. The EPA’s Toxic Release Inventory and Risk Management Plan regulations, for example, require companies to brief their neighbors on routine chemical emissions and worst-case accident scenarios respectively. Nothing else is required – whether, how much, and how to mitigate these risks is left to the voluntary decisions of companies, as influenced by the neighborhood’s reaction to the information. These two regulations are widely regarded as among the most effective EPA regs in reducing risk, even though they require no risk reduction. Similarly, the USDA has all sorts of voluntary nutrition recommendations. It mandates accurate nutrition information on food packages, which consumers are then free to act on or ignore. Cell phone distributors in many countries must label their products for EMF emissions, though the evidence on the health effects of these emissions is very scanty; once again, consumers may consider or ignore the information as they choose.

And the smallpox vaccination initiative of 2003 urged public health workers and emergency responders to roll up their sleeves, but left the final decision to them. Fewer decided to get vaccinated than the government had hoped, so in that sense the program failed. But it did empower them to make their own judgments about the comparative risk of getting vaccinated (a small, real, well-understood risk) versus the risk of going unvaccinated in the face of a possible smallpox attack (getting smallpox is very likely if the attack happens, but it’s anybody’s guess how likely the attack is to happen). By contrast, soldiers were required to be vaccinated, and the rest of us were forbidden to be vaccinated.

Another 2003 risk story was SARS. Five days after the SARS story broke, two days after the word SARS was coined, long before the virus was identified or the routes of transmission were clearly established, Canadian customs officers in Toronto wanted to wear masks and gloves. But Canada’s government would not provide them – apparently to avoid alarming travelers. Ron Moran, president of the Customs and Excise Union said: “It is very clear that what is predominantly in the employer’s concern is the whole question of image. They don’t want to create – in their words – ‘panic’ by officers wearing a mask. But there is a lot of uncertainty around this ... and our people are concerned.” The Customs and Revenue Department said Health Canada guidelines did not require airport staff to wear masks – as if that meant mask wearing was forbidden! Toronto taxi drivers, flight attendants, and driving instructors also wanted the option of wearing masks – but were either highly discouraged or forbidden from doing so. Officials were desperate to reassure people. But when people found their own ways to reassure themselves – such as by wearing masks – officials were contemptuous. In Singapore, by contrast, mask-wearing was actively encouraged, and colorful patterned masks became a fashion statement as well as a precaution. In a brilliant reframing of the situation, the Singapore government popularized masks as a courteous way of protecting others from the possibility that the wearer might be infected. (Jody Lanard tracked the mask issue during the SARS outbreaks in Toronto and Singapore, and provided the information in this paragraph.)

The Value of Voluntary Precautions

The reluctance of authorities to make precautions voluntary distorts the market, aggrandizes the authorities, infantilizes and disempowers the public, and dichotomizes the risk – all serious downsides.

The points about distorting the market and aggrandizing the authorities are probably clear enough without much further discussion. The essence of both market capitalism and political democracy is the conviction that when individuals are free to make their own decisions in their own interests (or what they take to be their own interests), things work out pretty well in the end. Companies that don’t want to look arrogant and over-reaching to their employees and customers take this lesson to heart; so do governments that don’t want to look arrogant and over-reaching to their publics and trading partners.

Even the most extreme supporters of free markets and free societies agree that there must be exceptions. And safety is an obvious exception. When something is clearly dangerous, governments have not just a right but arguably an obligation to protect the public, or at least to warn the public and strenuously urge it to protect itself. Companies have the same right/obligation vis-à-vis their employees, customers, and neighbors. But the decision to protect people from serious risks doesn’t tell you what to do when the risks probably aren’t serious. Protect people anyway? Refuse to let them protect themselves? Both of these extremes represent the very worst of bureaucratic self-aggrandizement, bordering on totalitarianism: Everything is either required or forbidden. Voluntary precautions are the middle ground.

As for infantilizing people, adulthood means making our own decisions, especially when the right answer is anybody’s guess. In the risk venue, adulthood means deciding for ourselves both how much risk we are prepared to accept and how much risk particular situations entail. Most importantly, adulthood means bearing the discomfort of making uncertain, debatable decisions, and bearing the outcomes if those decisions turn out badly. We make decisions for young children not just because we think they’re likelier than we are to decide wrongly, but because we think they cannot yet bear the uncertainty and the responsibility for bad outcomes. As they get older, we “let them make their own mistakes,” especially when we’re not sure what they ought to do in the first place. This isn’t just a matter of teaching them to decide wisely. It is also a matter of teaching them to be able to make and live with their own decisions, even when it’s not obvious which decision is wise.

Good parents do not let their children do unsafe things, of course. But they usually do let their children take unnecessary precautions. Suppose your child is having trouble sleeping because she fears there are goblins in the closet. A good parent doesn’t declare that quantitative risk assessment has shown the goblin risk to be de minimus, below regulatory concern, and that Sally must therefore turn out the light and go to sleep. A good parent lets Sally sleep with a light on. A good parent may even turn on all the lights, take Sally by the hand, and go on a goblin hunt – keeping to yourself your suspicion that there probably aren’t any goblins in the closet.

And that’s goblins and children! When the risk is less certainly non-existent than the goblin risk, and the fearful people are adults, the case strengthens for letting people take precautions that are probably unnecessary.

Precautions and Control

And what about when the risk is probably serious? In this situation, companies and governments (and parents) may appropriately require some precautions. But the fact that mandatory precautions are imposed doesn’t mean that there is no role for voluntary ones. Choosing from a menu of precaution possibilities gives the individual some control over his or her risk. For those who think the risk is fanciful and the precautions unnecessary, anger is reduced if they can exercise control by picking their precautions. And for those who think the risk is serious and the precautions essential, fear is reduced if they can exercise control by picking their precautions.

Voluntary precautions are empowering, and the absence of voluntary precautions is disempowering. This is true regardless of which side (fanciful risk or serious risk) your publics are on, regardless of which side you are on, and regardless of which side turns out right.

This is the other major reason we try to let our children start making their own decisions: People (even children) tend to get upset – outraged – when they feel they have no control over their situation. That makes them likelier to over-react to small risks, and likelier to have trouble bearing big ones. The importance of control in our emotional reactions to risk is well-established. At every level of actual hazard and every level of public concern, people handle the situation better if they are picking at least some of their own precautions.

For serious risks, I advise clients to try to offer an X, a Y, and a Z. “At least do X,” the company or government should say. “Even if you think we’re over-reacting, X is the minimum protection we think is necessary. We recommend Y. Y is more hassle and more costly than X, but it is also more protective than X. We think it’s worth it – but if you disagree and want to stop at X, okay. Z is still more bother and expense than Y, and again more protective. We don’t think it’s worth it; that’s why we recommend Y rather than Z. But if you think we’re not going far enough, if you feel more vulnerable than most people or more worried than most people, by all means go that extra mile and do Z, with our blessing.” (If there is a whole menu of X precautions, Y precautions, and Z precautions, that’s better yet.)

Two good things happen when you bracket your Y recommendation with an X and a Z. First, you get more Y. Because people feel more sense of control, they tend to be more willing to comply than when faced with a one-size-fits-all prescription. Second, you get less long-term rebellion. You have framed the choice of precautions so people who prefer X or Z to Y are still inside the system, not rebels. That makes them more receptive to your next precaution recommendation.

If you’re convinced the risk is trivial, there may be no X or Y – just a Z (or a menu of Z’s) for people who are worried anyway. Your job is to tolerate the people who prefer Z, even facilitate their implementation of Z, and keep any contempt you may feel to yourself.

If you think the risk might be serious, but not serious enough to require or strongly urge any precautions, then there’s no X; your minimum precaution is no action. You still ought to have a Y (the precautions you recommend) and a Z (stronger precautions for the people who think you’re under-reacting).

And if you’re pretty sure the risk is serious, then you need an X (the minimum – the precautions you’re requiring if you’re in a position to require anything, and pushing hard if requiring things is beyond your authority). You also need a Y (your recommended precautions, stronger than X) and a Z (still stronger precautions for those who think you’re under-reacting).

During the SARS outbreaks, for example, the U.S. Centers for Disease Control and Prevention (CDC) put out a set of minimum recommendations to cope with travelers returning to the U.S. from SARS-affected areas. It also put out a set of additional recommendations for companies and other organizations wanting to go beyond the minimum. One likely effect of the second set of voluntary precautions is that fewer organizations took still more extreme precautions: The CDC was giving them their Z. It could have done the same thing during the earlier anthrax attacks, but didn’t; the CDC’s Z for anthrax might have been getting but not filling, or filling but not taking, a Cipro or doxycycline prescription.

Of course the relationship between control and outrage is as true for companies and government agencies as it is for their publics and stakeholders. You may find yourself getting irritated at the idea that you might recommend stronger precautions than you require, or permit (and even facilitate) stronger precautions than you recommend. It feels good to those in charge to divide the precautionary world into the “right” precautions (the ones you require if you can, otherwise urge) and the “wrong” precautions (the ones you forbid if you can, otherwise ridicule). That’s the way for you to feel in control. But to help your stakeholders and publics feel in control instead, create a space for voluntary precautions.

Dichotomizing Risk

When authorities dichotomize precautions into the ones that are required and the ones that are forbidden, in effect they also dichotomize risk itself. Risky situations call for mandatory precautions. Situations that are not risky call for no precautions (also mandatory). The case for voluntary precautions is also the case for acknowledging – even insisting – that risk isn’t a dichotomy.

Dichotomizing risk might work out all right – very approximate but not crazy – if the dividing line of the dichotomy were someplace reasonable: a No-Observable-Effects Level (NOEL), for example, or a level As Low As Reasonably Achievable given current technology (ALARA). NOEL and ALARA don’t actually constitute a boundary between “risky” and “not risky” – there is no such boundary – but they do constitute two coherent dividing lines between the risks we have reason to confront and the risks we have reason to shrug off. But that’s not what usually happens. If people are going to see risk as a dichotomy, they’re far likelier to dichotomize at zero: Either the risk is zero or the risk is serious. Since zero risk is usually unattainable, and absolute confidence of zero risk is always unattainable, dichotomizing at zero leads to risk management standards that are also unattainable – not to mention costly, inefficient, and hypocritical.

Companies and government agencies complain incessantly that the public demands zero risk. (This complaint came up explicitly in all three of the case study examples I started the column with.) My answer is always the same. We set the public up to demand zero risk whenever we pretend to supply zero risk – whenever we use the word “safe” without a qualifier, for instance. Every time my waste cleanup client asserts that the tank vapors “do not threaten the health of our employees,” every time a water utility insists that it “will never compromise on safety,” every time a USDA spokesperson insists that “the U.S. beef supply is absolutely safe,” the unreasonable demand for zero risk is strengthened. Some in your audience actually believe your overstated reassurances; others, your committed critics, know better but find it useful to hold you to your false promises. Either way, when people argue that you can’t be sure the risk is zero [true] and you must therefore take additional precautions [doesn’t follow], you have no one to blame but yourself. Having conditioned your publics to feel entitled to zero risk, in short, you shouldn’t be surprised when they want you to deliver zero risk.

Similarly, people may well demand excessive precautions from a company or government agency that has over-promised on safety. Consider the phrase “every conceivable precaution” – as in “We are taking every conceivable precaution to protect our employees/protect the drinking water/protect the meat supply.” Anyone in authority who is actually taking every precaution he or she can conceive of either is taking far too many precautions or lacks the essential ability to conceive of more and decide whether to take them. The reality of precaution-taking is that there are some precautions so obviously wise that taking them is a no-brainer, and some so obviously unwise (too expensive, too disruptive, too ineffective) that not taking them is a no-brainer, though we can certainly conceive of them. Then there are the precautions in the middle, the tough calls. A decent risk manager can always list the precautions he or she decided to take but it wasn’t obvious, and the precautions he or she decided not to take (at least not yet) but it wasn’t obvious. If there aren’t precautions on your desk that are debatable in your mind, you’re not much of a risk manager.

We all know that – but we still feel tempted to assure our stakeholders that we are taking every conceivable precaution. Not surprisingly, they often end up conceiving of precautions we haven’t taken and demanding that we take them. Then we complain about how unreasonable they are.

The solution to all this is to point out again and again that risk isn’t a dichotomy and neither is precaution-taking; that it is always possible to do more (or less) about a risk; that you are taking the precautions you think best but it’s a judgment call in an uncertain situation, and you’re open to argument about whether you drew the line too far to one side or the other; and that you are recommending that we take the precautions you think best, but those who want to take more (or fewer) precautions are welcome to do so and could turn out right.

When you first come out of the closet acknowledging all this, people will no doubt criticize you for being an indecisive leader. They may very well blame you for their increased anxiety – as if they wouldn’t have been worried if only you had told them what to do. We do resent being infantilized, but that doesn’t keep us from also resenting being made to grow up. Hang in there. By all means tell us whether you think we should wear supplied air when working on the waste tanks, or whether you think we should drink the water after a possible terrorist attack, or whether you think we should buy beef from cattle that haven’t been tested for BSE. But also tell us it’s up to us. Save the forbidden precautions for situations where the precaution itself represents an unacceptable risk. Save the required precautions for situations where the risk is pretty clearly substantial – and even then list some voluntary precautions as well for those who want to go further. Give us as much control as you can by offering a menu of voluntary precautions whenever possible. We won’t necessarily thank you for it, at least not at first. But we’ll be better for it. And we’ll stop expecting the impossible from you.

Copyright © 2004 by Peter M. Sandman

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