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Science for Watershed Decisions on Abandoned Mine Lands: Review of Preliminary Results, Denver, Colorado, February 4-5, 1998

Science and Regulatory Practice: The Search for Certainty

By D. Kirk Nordstrom¹

Questions are often raised during the regulation and remediation of hazardous waste sites on how best to go about it, and scientists, engineers, and regulators are not always in agreement. The classic assertion is that regulators often think that scientists just want to do another study and that these studies are self-promoting, whereas scientists often think that regulators and remediation teams always want to rush the cleanup of a site before they have defined the problem and considered the consequences. Let's be honest—there is truth to both of these claims. Scientists do like to study problems out of pure curiosity and for prestige, and regulators do work with limited information, limited time, limited funding, and frequently with considerable political pressure to show results. Part of the problem stems from a misunderstanding of what science is, and another part stems from a misunderstanding of what is involved in regulation and remediation. Science is a way of understanding the physical world based on testing hypotheses with empirical evidence subject to open debate and peer review. Without science, there is no basis for regulation, or remediation, or testing remedial effectiveness. Remediation is the activity of correcting, curing, or ameliorating an unwanted problem. Environmental remediation is directed at specific sites with specific issues for which specific scientific knowledge is needed within a specific legal-political agenda. For complex sites, remediation is often experimental and needs focused scientific research that must be communicated to politicians and the public.

An example of a mine site where remediation failed because hydrology and wastes were inadequately characterized is contrasted with another mine site where mine plugging was avoided by applying scientific research to the possible consequences, which were found to be potentially dangerous. Technical advisory committees with broad multidisciplinary expertise can help considerably in eliminating undesirable consequences from remediation efforts.

The important questions are: Is the problem well-defined? This question addresses ultimately the known or potential risk to human and environmental health, but it also addresses what is known about contaminant sources, mobility, and fate. Has the right science been applied to the problem? The concern here is whether the appropriate scientific (medical, economic, and social as well as physical, chemical, biological, geological, hydrological, and ecological) disciplines have been used in a prioritized manner to emphasize the most relevant issues. Have we got the science right? This question refers to adequacy and reliability of the data, consideration of multiple working hypotheses, testability of hypotheses, plausibility of assumptions, and the magnitude and character of the uncertainties. Have we got the right stakeholder participation? This question addresses whether all parties who have some stake in the deliberative process have been included so that all important perspectives can be considered. Have we got the participation right? This question pertains to the adequacy and appropriateness of the response to the stakeholders and the improvement of trust. Have we developed balanced, informative syntheses? Overemphasis on analytical aspects can lead to failure without the synthesis of information communicated to the nontechnical public and decision-makers. Is there a defensible and consensual goal? Rational environmental problem solving will succeed if all parties involved share a common understanding of concepts, assumptions, remedial alternatives, potential consequences, and costs that are defensible and adequately constrained by empirical evidence. These guidelines, extracted from several publications on risk assessment, should minimize uncertainty and promote effective decision making.

¹U.S. Geological Survey, 3215 Marine Street, Boulder, CO 80303 (dkn@usgs.gov)

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