Commentary on Hassenzahl's ‘The effect of uncertainty on “risk rationalizing” decisions’

In 1995, my colleagues and I at the Harvard Center for Risk Analysis published the paper ‘Five-hundred life-saving interventions and their cost-effectiveness’ in the journal Risk Analysis (Tengs et al., 1995). As the title implies, it reported the cost per year of life saved of hundreds of environmental, occupational, transportation, consumer product safety and medical interventions. Interventions ranged from those that saved both lives and money, to those costing upwards of 10 billion dollars per year of life saved. We found, for example, that while the median medical intervention cost US$19 000 per year of life saved, the median environmental intervention cost US$4.2 million per year of life saved. The paper was greeted with enormous interest. Starting with a Wall Street Journal article titled ‘Prevention may be costlier than a cure’ our research has been covered by more than 20 media outlets including, The Economist, Business Week, Time, Harpers, and The New York Times. The Risk Analysis paper is ‘required reading’ in over 20 university courses in the US and has been replicated by researchers in Sweden (Ramsberg and Sjoberg, 1997) and Japan (Kishimoto, 1997) using economic data from their countries. I have received over 1500 preand re-print requests for this paper and it has been cited in the academic literature over 350 times. This paper and others (e.g., Tengs and Graham, 1996) featured prominently in recent discussions about how to reform the US regulatory system. In 2001 my co-author John D. Graham, Director of the Harvard Center for Risk Analysis, was appointed by President George W. Bush to serve as Administrator of the Office of Information and Regulatory Affairs in the Office of Management and Budget. President Bush charged Dr. Graham with the role of pursuing an agenda of ‘smarter regulation.’ Graham is working to ‘accelerate the adoption of good rules, modify existing rules to make them more effective and less costly, and rescind outmoded rules whose benefits do not justify their costs’ (Graham, 2003). Since Graham’s appointment, various scholars including Lisa Heinzerling of the Georgetown School of Law (2002) and Richard Parker of the University of Connecticut School of Law (2003) have published or circulated critiques of our prior research. David Hassenzhal’s contribution, ‘The effect of uncertainty on ‘‘risk rationalizing’’ decisions’ (Journal of Risk Research, 2003) is the most recent contribution in this vein. Dr. Hassenzahl claims that the cost-effectiveness estimates in our paper are ‘systematically arbitrary.’ He derives what he considers to be ‘equally plausible’ figures and expresses concern that policy ‘mistakes’ could be made if decision makers relied on one ordering of