12
Mai
2004

The economics of EMF guidelines/standards

To All

It seems that most, if not all standard setting bodies uncritically accept differing exposure limits for public / occupational exposures. Taking EMF for example, at 50 Hz the ICNIRP guidelines give 1000mG for residential and 5000 mG for occupational.

As ICNIRP is supposed to be a 'health based' guideline this seems a bit strange - making about as much sense as claiming that one has an increased biological resistance to environmental risks while in the workplace. - BUT the real issue is economics, not health. ICNIRP and its ilk made more sense when viewed as 'economics based' guidelines.

Currently the Australian Radiation Protection and Nuclear safety Agency (ARPANSA) has taken a responsible position by convening two committees attempting to come up with a revised Australian ELF standard, considering the 4 mG /doubling of the risk of childhood leukaemia evidence. I have presented the case that there is no valid scientific reason to differentiate between public and occupational exposures. Whatever standard limits are agreed upon, the limits should apply for one and all. Hopefully this does not mean that we all get saddled with the old 5000 limit!

As I see it the dual exposure system originates from the old "compensating wage differential" (CWD) which was promoted by Chauncey Starr for the nuclear power industry. Recommended reading is: "RISKY BUSINESS Nuclear Workers, Ethics, and the Market-Efficiency Argument" by Kristin Shrader-Frechette, from Ethics & the Environment Volume 7, Number 1
See: //www.iupjournals.org/ethics/ee7-1.html

I have copied and pasted a bit from my summary of this paper:

". . . Starr also mentions the concept of "voluntary" risk by individuals as a function of income benefits. In other words the acceptance of an increased risk in the workplace is an exponential function of his/her wage , or known as the compensating wage differential (CWD) originally formulated by Adam Smith. This assumption, with Starr as a main proponent, was to become enshrined in ionizing radiation exposure standards (as well as in other polluting industries) and later carried over to the non-ionizing exposure standards as well, where it is accepted that maximum exposure levels can vary greatly between public (involuntary) and workplace (voluntary) exposures. Starrs view has since been widely accepted among the risk assessment profession.

The compensating wage differential (CWD) has been justified on the grounds that workers in hazardous environments receive, as compared to other workers in less hazardous workplaces, a"hazard-pay premium", or as we call it in Australia "danger money". The theory being that the workers will willingly trade safety for extra wages. We see this enshrined in US legislation where, before 1990, ionizing workplace standards allowed nuclear workers to receive up to 10 times as much radiation in any year as a member of the public. After 1990 the public exposure limit was lowered but not the workers exposure. Thus allowing a workplace limit 50 times greater than the public . Starr (1969) justifies this on the grounds that occupational and public exposures to ionizing radiation are not analogous because environmental risks accepted 'voluntarily", through one's occupation, can be regulated by means of standards less strict than those of public risks, precisely because of the CWD. In other words, a classic economic solution of how to control occupational hazards. However a key ingredient for this assumption to work is that workers must have an adequate knowledge of their particular risk situations. By being aware of the risks involved then can then make decisions based on a wage differential. However, numerous surveys by risk assessors, including Starr have found that most people are generally unaware of the hazards they face, thus making CWD decisions impossible for those people.

Kristin Shrader-Frechette in the paper "RISKY BUSINESS Nuclear Workers, Ethics, and the Market-Efficiency Argument" details reasons for doubting that the CWD can provide an ethical justification for hazardous working environments because it may not even exist at all.

Some surveys have shown that when all workers are lumped together from lowest to highest paid, then risk and salary do increase as the CWD predicts. However when workers are separated into two groups, with white, male, unionized, college-educated, or skilled workers in a primary group, and the other being made up of non-white, female, non-unionized, non-college educated, or non-skilled workers in a secondary group, the CWD theory fails.

So while primary group workers enjoy a CWD, secondary workers do not. Hence, the alleged CWD for the entire grouping appears to me merely an artifact of data aggregation . In fact, the primary group CWD actually may exacerbate unequal treatment of those in the secondary group (non-white, female, non-unionized, etc.), because it covers up the lack of CWD in the secondary group, once the data are aggregated.

Shrader-Frechette points out that some surveys have shown that for non-unionized workers, there is a negative compensating wage differential; as risk increases wages get lower. When one compares wage rates across jobs, not adjusting for skill requirements, one observes that hazardous jobs pay twenty to thirty percent less than safe employment. Thus it is obvious that, even if there is a genuine CWD for some priviliged workers, the CWD may not provide general ethical justification for workplace environmental injustice, and this is especially the case in using CWD theory for standard setting.

Starr and other CWD proponents try to have it both ways when it comes to worker and public perceptions of risk in standard setting. They maintain that. Once employees are adequately educated regarding the risks they face, regulations ought to follow employees' risk preferences. In addition they would also say that regulators have no right to tell workers they cannot follow their preferences for higher risks. However, when these same proponents of the CWD wish to justify government imposition of a standard for public exposure they take the opposite tack. - Arguing, when faced with citizen's demands for stricter regulations on risks, that the public's risk perceptions, even of highly educated laymen, are subjective, intuitive, and generally inaccurate. CWD proponents would then argue that regulators should rely only on risk assessments calculated by the experts because these assessments are "rational" preferences.
. . . SNIP

Regards

Don Maisch


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