The Tolerability of Risk: A New Framework for Risk Management by F. Bouder, D. Slavin, and R. Löfstedt
The Tolerability of Risk. A New Framework for Risk Management , , and ( 2007 ). Earthscan , London .
Is The Tolerability of Risk a book what we have been waiting for? It certainly attempts to synthesize important and profound insights into the current debate on risk regulation. After the notorious aftermath of the BSE scandal in the United Kingdom and the tainted blood case in France during the 1990s, distrust in risk regulation increased. On the government level, this distrust was translated into a call for stricter regulation and an increased risk-averse policy. Precaution has been widely discussed and is even accepted in Europe as important attitude toward uncertain risks. However, notwithstanding the fact that the precautionary approach has its principle embedded in environmental law, it has remained a highly contested concept. It led to fierce debates in which opponents argued that the precautionary principle curtails more benefits by interfering in technological development. However, both advocates and opponents of a precautionary approach share a concern that current risk regulation needs reform.
The editors of The Tolerability of Risk book, Bouder, Slavin, and Löfstedt (2007), indirectly put the increasing dissatisfaction with risk regulation center stage by presenting the Tolerability of Risk Framework (ToR). The Health and Safety Executive (HSE) in the United Kingdom initiated this framework in the 1990s. In Chapter 4, author Jim McQuaid reflects on the historical context of the United Kingdom in which the ToR could develop. After a commissioned investigation, which showed the perceptional discrepancy regarding industry's health and safety performance between society and regulators in the 1970s, the findings of the appointed Robens Committee of Inquiry (1972) led to a new safety philosophy. This new philosophy advocated a more balanced view of state interests and those of risk imposers and was implemented in the Health and Safety at Work etc Act (HSWA) of 1974. In the years following the implementation, the regulator of the HSWA, the HSE, gained substantive experience in risk management. This provided a basis for the development of the ToR, which was published by the HSE in 1992. Other chapters in the book provide a detailed description of processes related to the ToR. In addition to the detailed elucidation of the framework, this book also aims to explore the possibility to apply the framework to other risk fields and other national contexts.
The Tolerability of Risk is a product of a conference on the topic, held in the Senate House at the University of London in March 2004. The conference workshop papers were developed into chapters, thereby combining academic and practitioner perspectives on risk regulation.
The book is divided into two parts: “concepts” and “experiences.” Despite the central focus on the HSE ToR framework as a means to explore alternative risk assessment and management strategies, the first and the most extensive part of the book (85 of the 140 pages) largely overlaps with the cogent White Paper on Risk Governance developed by Ortwin Renn. Part I, involving three consecutive chapters, reintroduces the conceptual analytical framework for risk governance developed by Ortwin Renn for the IRGC in 2001.1 The three chapters of Part I focus on the components of the risk governance framework, the risk handling chain, and wider governance issues (i.e., the inclusion of context), respectively. With his framework, Ortwin Renn challenges the existing, inherently probabilistic ways of dealing with risk. Whereas most risk management processes do not include the scope of the issue at hand and mainly examine classic components of risk handling such as organizational capacity and acceptability judgment, the risk governance framework also includes actor networks, social concern, and the political and regulatory culture when addressing broader risk characteristics. According to Renn, the incorporation of context is of utter importance when investigating risk governance structures in different risk domains and geographical areas.
Renn presents his framework as a starting point for academics, industry, and regulators, and all actors who have to deal with the assessment and management of risks (Renn, 2006). However, besides this general introduction, it is beyond the scope of this review to further discuss Renn's framework as such. Even more so since Renn's latest book Global Risk Governance—Concept and Practice using the IRGC Framework (eds. Renn & Walker, 2008), plunges more profoundly into the essences of the framework. Global Risk Governance starts with a summary of the original objectives and purpose of the framework. Thereafter, intensive peer review is incorporated. Then, with a more practical focus, the second part of the book is dedicated to the analysis of case-study applications of the framework and the yielded results. In this book, a wide array of case studies were applied and analyzed, ranging from nanotechnology to GMOs and nature-based tourism. The book concludes with the lessons learned from the critical reviews and the practical applications addressing the accomplishments of the IRGC and signifying challenges ahead. For those interested in the Renn-IRGC framework, we do not advise the ToR book, but refer them to the Global Risk Governance book. For academics, regulators, and people from industry acquainted with Renn's work, the added value has to be found in Part II of the book.
In Part II of the ToR book, “Experiences,” former and current members from the HSE take a detailed look at risk acceptability tools within the decision-making process that have been developed and used so far. First, as outlined before, Jim McQuaid describes “the historical perspective on the Tolerability of Risk,” elaborating on the development and importance of ToR within British society and risk regulation. Secondly, Tony Bandle's chapter “The Tolerability of Risk: The Regulator's Story,” provides the reader with a more profound insight into the regulator's perspective on the ToR framework. Then, Jean-Marie Le Guen reviews the implementation of the framework and its support by practitioners in his chapter, “Applying the HSE's Risk Decision Model: Reducing Risks, Protecting People.” Finally, Robyn Fairman explores the applicability of the ToR to other risk fields.
With these experiences, the editors intend to demonstrate the necessity for regulators and other practitioners to obtain “methodological guidance” when dealing with practical implementation of risk assessment policies. Important questions are: How feasible is the application of the HSE framework in this respect? What are its opportunities and limitations? The rationale behind the choice for the HSE framework is not to indulge in any promotional feast, but serves the purpose of explaining the practical value of a conceptual framework. ToR is presented as a framework that moves away from conventional risk assessment, in that it also considers putative consequences and scenarios. Its criteria are based on ethics, utility, and technology and thus account for uncertainty and social concerns, all congruent into a deliberative setting. All in all, the framework sounds very promising. The reader is furthermore provided with fascinating insights into practical experience in a case study on the chemical industry in Britain (Chapter 7).
From a broader risk perspective on risk assessment and management, this last chapter, “What Makes Tolerability of Risk Work? Exploring the Limitations of its Applicability to Other Risk Fields” by Robyn Fairman is most interesting. The HSE framework is part of the U.K. culture and embedded in a particular risk domain. It would be very interesting to explore whether expanded application is possible, moreover because in the introduction to the book it is stated that “this framework provides satisfaction to both the regulator and industry, as it simultaneously ensures high levels of compliance and manageable expectations. Fundamentally, this approach is an aid to consistent, transparent, risk-based decision making to communicate competence and address concerns” (pp. 3–4). This statement indicates that the ToR framework could be implemented outside the United Kingdom. The title of the book itself, The Tolerability of Risk—A New Framework for Risk Management, sounds equally suggestive of this expanded, or even universal application possibility. In view of these promises and claims, Fairman's chapter is the critical chapter of this book.
Fairman distinguishes and discusses two main prerequisites necessary to embed and apply ToR within other regulatory contexts. She argues that the application of the framework requires: (i) acceptance and legitimization by stakeholders of the need to balance risks against the costs involved in controlling them and (ii) a form of constitutional decision making that allows that balancing of risks and costs but ensures decisions are reached. She concludes that this complicates the acceptability of the framework beyond the British regulatory system as both requirements cannot be found in countries, or even in other risk domains within Britain, that adhere to a more rigid style of quantitative risk management. Her precautious conclusions are adopted by the editors in the final conclusion of the book. In view of this awareness of the limitations of the application of the ToR in other contexts, a more modest title would have been more appropriate. Especially, as the HSE-ToR framework has been, and still is, a very successful regulatory tool in a particular risk domain, in a particular regulatory context, the book would have gained attention even with a less sweeping title.
In conclusion, the merit of the book The Tolerability of Risk lies particularly in Part II. Notwithstanding some limitations concerning application of ToR in other risk regulation contexts, it is important that risk scholars and practitioners have the opportunity to gain access to an example of “good practice,” or perhaps even the best practice. We need such reconsultable accounts of “good” and “best” practices in risk assessment and management as a basis for further development of the field. Habegger (2008) provides another such reconsultable account with a description and evaluation of Swiss practice. We would like to strongly encourage such endeavors.
Furthermore, Bouder et al.'s book puts the theme “Tolerability of Risk” firmly on the agenda. In view of dissatisfaction with, and distrust in, risk regulation, tolerability issues deserve more attention in risk research and practice than they currently receive. Although the book does not live up to its self-generated high expectations, the Tolerability of Risk is most certainly an asset to the “risk library.”
