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Date: Fri, 10 Oct 2003 13:52:53 -0400
Reply-To: PSA Forum
Sender: PSA Forum
From: Edward Groth
Subject: Groth comments on Paper 1c, Risk Communication
Comments: To: fao.who.psaforum@WHO.INT
Content-Type: text/plain; charset="iso-8859-1"

Again, apologies to all for sending so many messages in one day. I will be "missing in action" (at a world consumer congress in Lisbon) for the next ten days, so you will have some relief!

Dr Kaye Wachsmuth has provided an excellent paper on risk communication. I agree with most of it, and would like to underscore a few points:

Regarding JECFA and JMPR, she articulates clearly needed improvements in terms of (i) communication between the expert bodies and their Codex committees, in both direcions (interactive communication), and (ii) more openness and participation by interested parties. With regard to the latter, Lisa Lefferts' paper on Transparency (2b) offers many detailed suggestions for improved access to the process (inclkuding but going well beyond the idea already discussed of open meetings). Certainly many of those suggestions might be feasible and would be helpful improvements if adopted. (I will comment later on Paper 2b.)

Dr. Wachsmuth describes the interactive communication between CCFH (which she has chaired) and JEMRA. This relationship offers a good model in some respects, and elements of what CCFH has done might be adopted by other Codex committees, with flexibility to tailor procedures to best suit the needs of the groups (Codex committee, expert body and stakeholders) involved.

In terms of recommendations, Dr. Wachsmuth offers some tentative suggestions for our reactions, and poses some questions for the Forum to answer. Here are my reactions (which include answers to the questions):

(i) She suggests considering requiring a declaration of strongly held views. I agree. The goal is to assemble a balanced, unbiased GROUP. This requires knowing and balancing where necessary the biases of individuals. It is not realistic to seek only unbiased individual experts (there are very few such!), but the group needs to be balanced, and this can best be achieved by explicitly paying attention to the need and ferreting out the biases.

(ii) She proposes including an industry and a consumer representative on committees. This mechanism should be considered (although simply opening meetings might achieve the same end). One need not assume that the added individuals would be non-scientists, however. Both industry and public-interest NGOs often have considerable expertise and (assuming other criteria were applied to exclude any conflicts of interest) such added members could quite possibly contribute substantively to deliberations.

(iii) She proposes holding an open session as part of the meeting of an expert body. This is an excellent idea and one that is relatively non-costly to implement. I strongly support a move in this direction.

(iv) She proposes an annual meeting of representatives from the expert bodies, adjunct to the annual meeting of Codex chairs and vice chairs. This is certainly one opition to consider; there may be others as well. But some kind of event at which Codex risk managers and expert risk assessors have the opportunity to interact and refine their mutual work agendas should definitely be part of the annual (formerly bi-annual) Codex cycle.

(v) She discusses the need for "a new vocabulary" and an integrated, science and risk-based food safety strategy. This sounds good as an abstract concept but the idea seems rather general and it's hard to envision what it might lead to in practice. Perhaps we could ask Dr. Wachsmuth to spell out in more detail what she had in mind.

(vi) She speaks of the need for a new "technology-forcing" effort (I'm not sure what that means) to set priorities for the work of expert bodies, among other things. I would be careful, here. Too much emphasis on quantifying and comparing risks could easily lead to a focus on evaluating problems where the best data exist, rather than those that may prove most serious in the long run. Sometimes large risks are still relatively uncertain and difficult to quantify. Such a risk-ranking system would need to include a factor for the magnitude of uncertainties and the risks of being wrong. I should also note that risk-ranking exercises have some inherent pitfalls, of which the most significant is that risks have non-biological components that affect their acceptability. A ranking based on expected mortality and morbidity would not, in itself, be sufficient to set priorities. Some risks that are objectively rather large are perceived as voluntary or avoidable or natural and therefore are relatively acceptable, whereas other risks that are objectively rather small may be much less acceptable, because they are involuntary, because they result from a new technology that benefits a few corporations or individuals but puts everyone else at risk, or for other reasons related to ethical and value perceptions. A ranking system that failed to take into account such ethical and value dimensions of risks but set priorities based on morbidity/mortality risk, might be seen (with some justification) by at least some part of the public as irrational. Based on my own experience with risk-ranking systems, my very subjective opinion is that they require a great deal of effort to "get it right" (or to reach a consensus that it's "right,") and that the effort might be better spent simply managing risks. The idea of setting "rational" priorities may be appealing but elusive and there is not much evidence that the current, admittedly imperfect priority-settng system is mis-allocating resources, at least at the level of WHO and FAO. (Such priority debates have more resonance in the US, the context for the Taylor et al. report Dr. Wachsmuth refers to.)

(vii) She speaks of a need for a "more understandable and harmonized vocabulary and technology to describe outputs of scientific advice." Perhaps this would include the centralized clearinghouse of expert food safety assessments that might be assembled by WHO and FAO, which I mentioned in earlier comments on Dr. Merlin's remarks? Governments could then use such an information source to manage risks at the national level. I would also note, however, that the current mood in Codex is fairly contentious and that there may be resistance to attempts to harmonize risk assessments. The effort at CCGP to develop "Working (General) Principles for Risk Analysis" was very difficult and was able to progress in the end only when it was agreed that the "principles" elaborated would apply only to work by Codex Committees. The effort to take these principles to the next stage, advice to member governments, has to date been stymied by the reluctance of many governments to accept "principles" that they feel could be used by some countries to justify standards that might adversely affect the resisting governments' national interests as food exporters. I fear that trade concerns might similarly override the willingness of many governments to accept harmonized risk assessments, at least when those expert assessments tended to suggest a need for more stringent risk-management measures than food exporting nations were willing or able to attain. This may not be a reason not to try to integrate and harmonize risk assessments, but we should be realistic about what we hope to achieve.

Which is to say, I suppose, that better communication is essential, but only gets us so far. Nonetheless, I believe most of the ideas in Dr. Wachsmuth's paper are very worthy and deserve to be pursued. I am least enthusiastic about risk-ranking but agree that it is at least in theory possible to do this soundly and in useful ways.

Edward Groth III, PhD
Senior Scientist
Consumers Union of United States., Inc.
101 Truman Ave.
Yonkers, NY, 10703-1057 USA
Phone: 1-914-378-2301
Fax: 1-914-378-2908
e-mail: groted@consumer.org