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COUNTRY CORNER
Penny wise and pound foolish; a regulatory approach to life
By Chuck Lay, Today's Farmer editor

John Graham has a shot at history. Graham is a man capable of revolutionizing regulation. That's because he's a world-class figure in risk assessment. He's the founding director of Harvard's Center for Risk Analysis, part of the Harvard School of Public Health. President George W. Bush nominated Graham to be administrator of the Office of Information and Regulatory Affairs at the Office of Management and Budget. It's a key position, one in which Graham can influence regulation on the front end. In early July, his nomination awaited action in the U.S. Senate. The switch in party control put his nomination status on hold, temporarily. But if there's any justice in Washington, Graham will be confirmed. The country will benefit.

That's because Graham likes to analyze risk, likes to put risk in perspective. He wants to bring his analytical approach to the formation of regulation. Regulation, after all, at its most basic level can be a good thing. Regulation is designed to control risk in society. Government has a legitimate role in regulating risk. The trouble comes when people lose perspective.

In our risk-averse society, regulation has assumed the status of religious fervor. Congressional blessings become thoughtless ritual. In just the past five years, 21,653 rules were submitted to Congress. 21,652 survive. It's time to re-examine that ritual.

Legitimate argument should focus on how inclusive regulation should be. No rational person argues there is a regulatory continuum on which risk disappears and life ends only with natural death. So how do we decide what's enough? What's too much? The debate should play out against a background of risk assessment, according to John Graham.

Risk assessment, when applied to regulation, certainly considers quality of life, despite what detractors say. But it also factors monetary costs tied to reducing risk, extending life or saving life. The analysis holds several truths self-evident: not all risk is avoidable (accidents happen); risk is relative (everything poses a risk - but some things are more risky than others); wealthier is healthier (health and life expectancy are directly correlated to living standards); prioritizing risk saves lives (focusing on the tiger at hand is smarter than hypothesizing about theoretical tigers).

With those assumptions in mind, consider that just one benzene regulation imposed by EPA costs U.S. taxpayers $168 million to prevent one theoretical death. An EPA regulation on a water-quality standard aimed at a specific chemical costs taxpayers $653 million to prevent a theoretical death.

Consider that for the same $168 million, you could put 3,064 police officers on the street, making life safer and longer for hundreds of people. A mere $653 million would put 10 brand-new fire trucks in every U.S. congressional district in the nation.

If the intent of these EPA regulations is to extend life, save life or reduce risk, neither is cost effective.

Guys like John Graham do the math. They don't hesitate to point out that we squander billions to prevent negligible, hypothetical risk while ignoring cost-effective solutions that provide real and immediate benefit. Analysis helps us spend money wisely or not at all. It's simple but amazingly controversial.

Make no mistake. Risk assessment is not foreign. Each one of us assesses risk daily. The quite serious risk posed by traffic does not prevent most of us from driving. Benefits exceed risks.

The trick is in applying that rational approach to regulation. John Graham can help by focusing our thought processes. And if the U.S. Senate heeds Mark Twain's advice, they can do the right thing. "This will gratify some people and astonish the rest."

 AUGUST 2001
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