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Cost-benefit Analysis (CBA) |
Costs and benefits of projects/policies are identified and reduced to a stream of monetary values that can be compared. Most often applied to large capital projects. Much academic debate about how to analyse the costs of topics such as lives saved or environmental impacts. |
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HACCP(Hazard Analysis Critical Control Point) |
Devised in 1973 in the USA, HACCP is 'a structured approach to assessing the potential hazards in an operation and deciding which are critical to the safety of the consumer. These critical control points (CCPs) are then monitored in situ and specified remedial action is taken if any deviate from their safe limits'. Provides a more structured approach than traditional inspection and quality control procedures. |
Health and Safety at Work Etc Act |
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Placed a duty on employers to reduce risks to workers and the public 'so far as is reasonably practicable' - analogous to 'As Low As Reasonably Practicable' (ALARP), a key risk assessment concept. |
Risk Assessment: a Study Group Report (Royal Society) |
Risk perception, risk-benefit analysis, NOAEL, ALARP, ALARA |
Focused on the examination of risk perception based on the psychology of the public and the use of risk-benefit analysis in the management of risk and allocation of resources. Mentioned NOAEL (No Observable Adverse Effects Level) for toxicological substances, and compared ALARP with the less stringent ALARA (As Low As Reasonably Achievable) principle. Noted (in the context of biological risks) that: 'The UK regulatory authorities have long recognised . . . that it is impossible to give an assurance of "complete safety" or "zero risk" '. |
Investment Appraisal in the Public Sector (Treasury 'Green Book') |
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Provided a methodology for appraising the costs and benefits of options for proposals involving public expenditure. Usually envisaged as applying to capital projects. Recognised the importance of sensitivity analysis in the handling of uncertainties, and noted that where changes in assumptions could seriously affect the ranking of options, sensitivity analysis could help to identify which assumptions were crucial. |
Royal Commission on Environmental Pollution, 10th Report: Tackling pollution - experience and prospects |
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'Evidence that is not conclusive when judged by the conventions adopted in scientific research may yet be reasonable cause for concern to those who have to act on it outside the laboratory. The politician or manager who must decide what action to take now cannot wait for the rigorous proof that is properly demanded by the referee of a scientific journal. For those responsible for the well-being of the public and the protection of the environment there will sometimes be a difference between what can be believed with confidence and what in the absence of certainty it is prudent to assume.' (Quoted in the 12th Report of the Royal Commission on Environmental Pollution: Best Practicable Environmental Option, London, HMSO, 1988, p. 11, para. 2.30.) |
Guidelines to the Establishment of Hazard Analysis Critical Control Point (Campden Food Preservation Research Association, Technical Manual No. 19) |
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Advice on how to undertake on an HACCP analysis in the food production industry. Aimed at managers. Many British food companies had already implemented the HACCP approach, although in a less formalised manner. |
The Tolerability of Risk from Nuclear Power Stations (Health and Safety Executive) |
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Response to a recommendation of the public inquiry into the proposed Sizewell B nuclear power station. Explained the Tolerability of Risk principle, distinguishing between: risks which are so great as to be unacceptable;
risks that should be reduced to ALARA or ALARP; and
risks so small that no further precautions are necessary.
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Royal Commission on Environmental Pollution, 12th Report: Best Practicable Environmental Option |
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Restates (p. 11) what the Royal Commission had said about the precautionary principle in its 10th Report in 1984 (see above). Describes 'The Vorsorgeprinzip [precautionary principle] in West German Environmental Policy', noting that this is limited by the further principle of Verhältnismäßigkeit [proportionality], which 'excludes any attempt to eliminate all environmental disturbances since such action would appear to be excessive in relation even to the goal of Vorsorge' (p. 62). |
Establishment of MAFF Consumer Panel announced |
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Chaired by the Minister for Food Safety and attended by the Heads of the MAFF and DH Food Safety Directorates. Objective: 'To keep under review from the consumers' viewpoint the implementation of policies on food safety and consumer protection.' The Panel considered papers on food safety risk assessment in 1990, 1991 and 1992. |
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Mr Brian Dickinson (MAFF Grade 3) joined the Food Safety Group and learned that 'for chemical risks in food (additives, contaminants and residues) there were well-established methods for assessing any toxicological risks and determining No Observed Adverse Effect Levels (NOAEL)' (S97B Dickinson p. 4 para. 11). Confirmed by Dr William Denner, MAFF Grade 3 Chief Scientist (Food) (S435 Denner p. 5 para. 10). |
Part I of The Microbiological Safety of Food (Report of the Richmond Committee) |
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The Committee's remit was to advise the Government on the microbiological safety of food. They recommended that 'all food processes should be designed on HACCP principles operated by properly trained staff using validated control programmes in premises with appropriate hygienic facilities' and that this should be encouraged by local authority officers in inspections. (Report Part I: p. 111, recommendation R7.5.) |
Inter-Departmental Group on Public Health (IDGPH) - first meeting |
Risk assessment/risk perception |
Chaired by the Chief Medical Officer and comprising Grade 2 departmental representatives. Set up after an interdepartmental review of the allocation within Whitehall of responsibilities for public health, especially food safety. Agreed at first meeting (22 February 1990) to look at risk assessment and the relationship between public perception of hazards and scientific evidence (YB90/02.22/13.1-13.4). |
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Noted a difference between actual and perceived risks of different transport modes, that public concern about the safety of public transport involved factors additional to those of economic appraisal and risk analysis, and that 'there were other areas in which public perception of risk was at variance with the scientific evidence' (YB90/05.14/14.1-14.3). |
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Considered a paper on risk assessment and risk management in MAFF, noting that risk assessment and comparison could be used to prioritise so that areas of greatest food safety concern could be examined first, and that there was a need to improve risk communication 'to bring about a more rational public perception of food-related risks'. Agreed that 'it was particularly difficult to adopt a scientific approach in the areas of food safety in view of . . . the public's often irrational approach to relative risks'. Also considered a DH paper on the economic assessment of environmental health risks (YB90/10.08/6.1-6.3). |
Environment Protection Act |
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Introduced principle of Best Available Technology Not Entailing Excessive Cost (BATNEEC), which recognised (a) the problem of the cost of risk reduction and (b) the extent to which a reduction in risk has to be traded off against other basic goals. The corollary of (b) is that increases in safety must normally come at the expense of other valued objectives such as wealth creation, international competitiveness, etc. |
Part II of The Microbiological Safety of Food (Report of the Richmond Committee) |
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Commended the use of HACCP 'for the slaughterhouse as for all other stages of food production', and stressed 'the important contribution that can be made by microbiological monitoring, as an adjunct to the (HACCP) approach'. (Report Part II: p. 63, paragraph 4.45.) Reproduced an assessment by the International Commission on Microbiological Specifications for Foods (ICMSF) of the critical control points in the red meat production chain (p. 54). |
Conference on risk and risk assessment in food |
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Organised by MAFF. Attended by DH, MAFF and NCC (National Consumer Council) representatives. Discussed the regulatory machinery of risk assessment and risk management methods. The NCC gave a presentation on risk perception by the public, focusing on the development of ways to review consumer knowledge, how risks are perceived, and how to develop and test information strategies. |
Economic Appraisal in Central Government (Treasury) - revised edition of 1984 'Green Book' |
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Now contained an 'Appraisal Checklist' and an annex on risk and uncertainty which highlighted the role of sensitivity analysis, defined as the calculation of how changes in particular assumptions would affect net present values, total cost, or other project outcomes. Seen as relevant to capital projects and spending programmes, but provided a 'structured thinking' framework which could apply to policy options. |
Policy Appraisal and the Environment: A Guide for Government Departments (DoE) |
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Offered a 'systematic approach to the treatment of environmental issues within policy analyses', ie, a 'structured thinking' framework. Illustrated how sensitivity analysis could be applied to policy issues. |
'Practical Food Safety for Business' (MAFF/DH guidance leaflet) |
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Reminded food businesses of their legal obligations on food safety. Described how HACCP worked and could be used. |
Inter-Departmental Liaison Group on Risk Assessment - first meeting (10 April) |
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ILGRA was set up to fulfil a commitment in the Government's This Common Inheritance: the Second Year Report 'to review the principles and practices used in Government for risk assessment with a view to identifying best practice and encouraging common approaches where appropriate'. Chaired by HSE; members from MAFF, DH, DoE, Treasury and DTI. |
Risk: Analysis, Perception and Management (Report of Royal Society Study Group) |
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Updated the Royal Society's 1983 Report. Chapters on approaches to taking account of individuals' perceptions of risk and values, and on risk management and taking account of diverse opinions. Both made the point that taking account of public views meant making political choices as well as accepting scientific choices. |
MAFF Consumer Panel - tenth meeting (8 April) |
Risk prioritisation 'tool kit' |
Considered paper on 'Risk Assessment and Risk Management in Food Safety: Making Judgements about Food Related Risks'. This reviewed a computer-based approach to food risk prioritisation, 'Hi-view'. MAFF commissioned from the Centre for Environmental and Risk Management at the University of East Anglia a risk prioritisation 'tool kit'. |
'Move to less burdensome meat hygiene rules announced' by MAFF (22 October) |
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MAFF announced plans to move towards a system of meat hygiene controls based on risk assessment (YB93/10.22/1.1-1.2). This followed advice to Ministers in March 1993 that 'particularly on the food hygiene side, we should press firms to adopt a risk-directed approach such as HACCP . . . and should go for this rather than a regulatory approach' (YB93/3.19/1.1-1.11). HACCP was part of this policy (cf. December 1993 meat hygiene strategy document mentioned below). |
Regulation in the Balance: A Guide to Risk Assessment (Deregulation Unit, DTI) |
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Restated techniques of risk assessment and risk management in the context of regulation: ' . . . risk assessment enables the policy options to be appraised and evaluated.' Noted that 'there is always some uncertainty surrounding any assessment . . . (this) can often be assessed satisfactorily by "sensitivity analysis", where information and assumptions are varied within realistic limits and the effects can be seen. In addition, 'regulation must also be proportionate to the problem . . . it is a mistake to try and regulate against all risks.' |
Report of the MAFF 'Risk Perception and Communication Audit' |
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MAFF had commissioned external researchers to examine its approach to risk communication. Their Report recommended that the Food Safety Directorate should review its risk communication strategy, to examine how to monitor public risk perceptions and reactions to risk communications in a cost-effective and reliable manner. |
MAFF Meat Hygiene Research and Development Strategy (13 December) |
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Further to the October 1993 announcement on meat hygiene controls (see above), this strategy document considered how MAFF saw meat hygiene controls developing. It envisaged 'a shift of emphasis . . . away from traditional meat inspection techniques, towards other approaches, specified according to how identified public health risks can best be minimised'. It also stated that: 'A structured programme of R&D will be developed, to help the application of HACCP methodology to the slaughter and processing of individual red meat species' (YB93/12.13/4.1-4.9). |
A Guide to Risk Assessment and Risk Management for Environmental Protection (DoE) |
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'. . . by approaching the problem systematically we shall avoid many mistakes and by recording carefully how we make our assessments, we shall be able to learn from the mistakes we are bound to make.' Included discussion of the precautionary principle and its relevance to risk assessment. Noted that 'at every stage of a risk assessment and risk management study, assumptions should be made explicit so that any further review can establish whether the situation has changed sufficiently to warrant modification'. |
Policy Appraisal and Health: a guide from the Department of Health |
Risk assessment/sensitivity analysis |
Guidance on identifying health impacts of policy options, assessing their magnitude, estimating costs, and identifying uncertainties and testing the robustness of options by means of sensitivity analysis. |
Deregulation Task Force 1994/95 Annual Report: The Government's Response |
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Accepted the recommendation that a risk assessment should be required for all regulatory proposals affecting business. |
Use of Risk Assessment within Government Departments (ILGRA) |
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Identified a need for greater consistency and coherence across government in those areas where risk assessment is used, and made a number of recommendations for achieving this. Risk assessment provided a necessary structure for rationalising decisions on risks that society was prepared to accept. Such acceptance had to take account of values established by political debate and public willingness to tolerate risks in return for benefits. However, for the tool to work, those who relied on it to inform their decisions had to understand its nature and limitations; that it related to hypothetical rather than real persons; and that the assumptions were value-laden and subject to uncertainties which needed to be exposed. |
The Setting of Safety Standards: A Report by an Interdepartmental Group and External Advisers (Treasury) |
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A companion to the ILGRA report noted above. It concluded that Departments needed to develop consistent frameworks for setting safety standards and should take account of consumers' preferences. More data were needed on the reasons for those preferences. |
Safety in Numbers? Risk Assessment in Environmental Protection (Parliamentary Office of Science & Technology) |
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Reviewed the current practice of risk assessment and considered its use in the future, especially in the field of environmental protection. Considered the use of the precautionary principle to deal with uncertainties, citing the definition by the 1992 Earth Summit: 'Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.' Also considered the impact of deregulation on risk assessment, and whether it gave greater weight to short-term costs than to longer-term environmental benefits. |
Further revised edition of the Treasury 'Green Book' - Appraisal and Evaluation in Central Government |
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Explicitly encouraged the use of risk assessment in relation to non-financial proposals such as policy development and the specification of standards. |
Communicating About Risks to Public Health: Pointers to Good Practice (Department of Health) |
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Recognised a change since the 1960s from emphasising 'public misperceptions of risk' ('which tended to treat all deviations from expert estimates as products of ignorance or stupidity') towards seeing risk communication as a two-way process in which expert and lay perspectives should inform each other. Noted the need to earn public trust and to be clear about aims. Assumptions needed to be made explicit and open to re-examination. 'There is no justification for presuming that messages will always be understood or disbelieved, and that nothing can be done to mitigate this.' Included discussion of 'fright factors' and 'media triggers', significant factors underpinning risk perception by the public. |
Risk Communication: A Guide to Regulatory Practice (ILGRA) |
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Set out four principles to help Departments look critically at what they do and improve the way they communicate about risks; '...communication needs to be considered as an essential and integral part of risk regulation, and as a two-way process, not simply as a matter of imparting information.' Communicating in a crisis was important. Departments should be prepared in advance for dealing with crisis situations, identifying (a) key scenarios; (b) key stakeholders; (c) infrastructure/systems/procedures; and (d) what information material would be needed. They should also apply the ECCB test (Empathy, Concern, Commitment, Benefit). |
