Comments on Dr. Finkel's Paper on Solution Focused Risk Assessment (SFRA)

In this issue of the journal, Dr. Adam Finkel presents his proposal that it is time for risk assessments to be prepared or used in a different manner. Specifically, he notes that “more attention and resources have been expended on dissecting problems than on implementing actual solutions that reduce risks.” He follows this thought by suggesting that those of us in the risk assessment community adopt a new term or approach called “solution focused risk assessment” (SFRA). Dr. Finkel is no stranger to the field of risk assessment and is well respected (Paustenbach 1989a,b). He has made many contributions over the years, and he has challenged many of us to reflect on the way the field is practiced and how data should be interpreted. More than most other scientists, he has questioned whether the confidence that some of us have in the process and its results are warranted. This questioning has, in my view, raised the quality of assessments conducted over the past 20 years. Thus, I believe all of us should give consideration to his proposal. For my part, I have tried to stay abreast of both the theory and practice of risk assessment since the day I was asked to review the NAS Red Book in 1982 (NRC 1983). Since then, my colleagues and I have probably conducted more than 1,000 assessments of chemicals or radionuclides in contaminated soil, sediments, air, water, and a host of consumer products (Paustenbach 1989a,b; 2002). As I read Adam’s article, and I have read it several times, I tried to understand how his ideas would change the daily practice of our field. The premise of Dr. Finkel’s proposal is that we should move from having risk assessments identify not problems, but, rather, decisions. He indicates that scientists and decision makers have been incorrect in believing that “you cannot think about solutions before you fully understand the problems.” He proposes that scientists “must change the timing of when risk assessors consider risk management solutions, and may change the nature of the solutions considered.” He suggests that it would be better if “alternative risk management pathways are arrayed before scientific analyses of exposures, potencies, and risks begin . . . in order that these analyses can focus on the risks (and costs) of specific actions.” I believe that Dr. Finkel has again challenged us by offering a novel suggestion that may have merit, especially in certain situations in which a genuine problem not only exists, but where the majority of scientists or regulators believe that it also deserves to be remedied in a timely fashion. The following are a few views that I hope will offer insight from the perspective of someone who has had the privilege of working in the field nearly every day for 30 years.