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Comment on “Solution-Focused” Risk Assessment

Adam Finkel’s article is a useful contribution to thinking about risk. Like almost all of Adam’s writings, it is thought-provoking in the best sense of that term. Although I have not talked with Adam about why he wrote the article, I suspect he is responding to the continual erosion of environmental health and safety regulation and the continual improvement and refinement in risk assessment methods. The two things are only remotely linked—the erosion of regulation is due primarily to a rightward shift in the political spectrum, the obsolescence of the legislative framework, and tectonic changes in campaign finances that have given regulated industries control over the political process. That said, an examination of the risk assessment–risk management relationship is still of great importance. The relationship has never been simple or easy either in theory or practice. Even the Red Book (NRC 1983), which Adam cites as the source of the separation of risk assessment and risk management, is ambiguous (and perhaps ambivalent as well). Although the Red Book has an executive summary that strongly emphasizes the assessment–management separation, the main recommendation and large parts of the text say that the two neither can nor should be separated (see Davies 2003). After several decades of experience and debate, there is now general agreement that risk assessment and management are and should be intermingled. As Adam notes, the process is “recursive”—“more information about risk refines the solution set and more information about solutions directs the analysis toward specific knowledge gaps and uncertainties.” As he notes, “thinking about solutions should occur in parallel with thinking about problems.” Adam goes further, however. The core of his message is the importance of starting the interactive process with a focus on solutions rather than a focus on determining risk. Both risk analysis and cost–benefit analysis are necessary, but the analysis will be of limited utility or even counterproductive if it fails to start with the broader task of identifying potential risk-reducing solutions. Can Adam’s solution-focused paradigm help to make regulation more effective? I think that in many situations it can. Solution-focused risk assessment aligns the interests and focus of the risk analysts much more closely with the interests and focus of decision-makers. Instead of pursuing separate agendas, the assessors and decision-makers would share a common interest in solutions. This would change the nature of risk assessment research and practice. New questions and techniques would arise. Instead of ever more exquisite