A Commentary on Dr. Finkel's Proposal for Solution-Focused Risk Assessment

I was asked by HERA’s editors-in-chief to comment on whether Dr. Finkel’s proposal for solution-focused risk assessment (perhaps “solution-focused risk management”?) would, if enacted, be superior to the current risk assessment/risk management paradigm. My initial reaction, not being a party to whatever discussions and controversies this proposal has undoubtedly already engendered, is that it points out some deficiencies in our current practice of risk assessment and risk management, particularly the tendency to analyze a problem rather than start moving to address it. In the current paradigm, a problem (typically the negative consequence of a past decision) comes to light—the “signal of harm”. Decision-makers are then faced with determining whether this problem, if not addressed in some way, could lead to, or continue to yield, negative consequences in the future. Similarly, if a new activity, process, or product is being proposed, decision-makers must consider (but how often do they?) whether it, if implemented, might eventually lead to negative consequences. In either instance, decision-makers and stakeholders must recognize (or anticipate) a problem and agree that it is (or could be) of sufficient significance to require a response (or a change in the proposal). At present, risk assessment (or more typically a conservative dichotomous hazard assessment) is the tool used to establish both the existence and the “strength” of the harm signal—decisionmakers must then ponder whether it is strong enough to suggest the need for some action. Establishing the nature and extent of this signal (or even its very existence), particularly for high-profile problems, can be a very polarizing and paralyzing process, as extreme policy positions (e.g., from no-action to the highly precautionary) may deny or magnify its existence, as well as manipulate, criticize, and impede the risk assessment, in hopes of furthering their differing, diverging agendas. Dr. Finkel would have us proceed from signals of harm (as evidenced by “ . . . adverse findings from one or more bioassays, epidemiological investigations, or observations of adverse ecological change . . . ”) to the sources of these signals, to identifying a wide range of alternatives (including no-action) to change these sources, and finally to a choice among alternatives based on overall risk (his Figure 1). As he points out: “Risks arise because sources of risk exist . . . ” Once a