Policy Analysis

pubs.acs.org/est

Integrated Assessment of Risk and Sustainability in the Context of

Regulatory Decision Making
Ken Sexton*, and Stephen H. Linder

University of Texas School of Public Health, Brownsville Regional Campus, 80 Fort Brown AHC, Brownsville, Texas 78520,
United States

Institute for Health Policy, and Division of Management, Policy & Community Health, University of Texas School of Public Health,
1200 Herman Pressler Street, Houston, Texas 77030, United States
ABSTRACT: Risk assessment is a decision-making tool used by the
U.S. Environmental Protection Agency and other governmental
organizations to organize and analyze scientic information so as to
examine, characterize, and possibly quantify threats to human health
and/or ecologic resources. Sustainability evaluation is a process for
organizing and analyzing scientic and technical information about
naturesociety interactions in order to help decision-makers determine
whether taking or avoiding certain actions will make society more
sustainable. Although development and application of these two
methodologies have progressed along distinct and unconnected
pathways, the National Research Council recently recommended that
the U.S. Environmental Protection Agency adopt the concept of
sustainability as both a process and a goal, and that risk assessment be incorporated, when appropriate, as a key input into
decision-making about sustainability. The following discussion briey reviews these two analytic approaches and examines
conceptual frameworks for integrating assessments of risk and sustainability as a component of regulatory decision-making.

INTRODUCTION
The risk assessmentrisk management (RARM) paradigm
adopted by the U.S. Environmental Protection Agency (EPA)
for regulatory decision-making involves three complementary
and overlapping phases.13 First, risk-related research is
conducted to provide necessary scientic data and knowledge.
Second, systematic evaluation of available scientic information
is undertaken to estimate the likelihood, severity, and
uncertainty of risks. And third, facts and values are weighed
as part of management decisions about which risks are
unacceptable and what, if anything, to do about them. A
fourth phase, risk communicationexplaining risks and riskrelated decisions to stakeholders and responding to their
concerns and questionsis also often included as part of the
RARM paradigm.4,5 The paradigm, including both the
framework and its implementation, has evolved over the past
three decades as newer, more complicated and costly to solve
problems were identied, advancements in scientic knowledge
improved causal understanding about environmentally related
diseases, and enhanced analytical methodologies became
available to measure both exposures and eects.18 Today,
the RARM paradigm is a formalized, systematic process that
has been used to make regulatory decisions about hundreds of
environmental, mainly chemical, threats (e.g., acute and chronic
adverse eects, negative consequences of accidents, like res
and explosions) to human health and environmental quality. So
far, EPA has promulgated ocial risk assessment guidelines for
carcinogenicity, mutagenicity, developmental and reproductive
2014 American Chemical Society

toxicity, neurotoxicity, chemical mixtures, exposure assessment,

and ecological risk.3
Over this same time period, a parallel evolution was taking
place, primarily outside the EPA, involving the concept of
sustainable development or sustainability and its application
to decision making. The basic denition of sustainability
development that meets the needs of the present generation
without compromising the ability of future generations to meet
their own needswas established by the Brundtland
Commission in 1987,9 and endorsed by the 1992 Earth
Summit in Rio de Janeiro.10,11 The global commitment to the
goal of sustainability was rearmed in subsequent United
Nations conferences, including those at Johannesburg12 in 2002
and Rio de Janeiro13 in 2011, and currently more than 100
countries, including the European Union, have developed
national strategies for attaining sustainable development.
Presently, the United States has no national sustainable
development strategy or comprehensive policy, relying instead
on ad hoc policies emanating from the White House. In January
2007, President G.W. Bush issued Executive Order 13423
making it the policy of the U.S. that Federal agencies conduct
their activities ...in an environmentally, economically and
scally sound, integrated, continuously improving, ecient, and
Received:
Revised:
Accepted:
Published:
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September 26, 2013

January 7, 2014
January 13, 2014
January 13, 2014
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activity, event, or technology promotes an outcome that is

consistent with (or contributes to) dened sustainability
objectives
envisions sustainability as an array of societal goals and
measures economic, environmental, and social contributions to achieving those goals

are we headed in the right direction compared to baseline conditions?

activity, event, or technology leads to a more sustainable outcome compared to

current baseline

takes a triple baseline perspective to ensure that negative impacts are not
economically, environmentally, or socially unacceptable

(a) determining relevance of baseline conditions for sustainability, (b)

measuring deviations from baseline, (c) making trade-os between economic,
environmental and social conditions

central
question

acceptability
criterion

conceptual
framework

challenges
(a) setting economic, environmental and social goals that
reect sustainability, (b) measuring progress toward stated
goals

are we headed in the right direction compared to dened

goals?

to maximize economic, environmental, and social outcomes

by comparing results to established goals

to minimize adverse economic, environmental, and social eects by comparing

outcomes with baseline conditions

objectives-oriented
conduct an objectives-led strategic environmental assessment
before the activity or event has taken place

aims

baseline-oriented

conduct a project-based evaluation after the activity or event has taken place

applications

characteristics

types of integrated sustainability evaluation

Table 1. Three Ways to Conceptualize Integrated Sustainability Evaluation, adapted from Pope et al.17
comprehensive

(a) establishing a practical denition of sustainability, (b) dening meaningful

criteria for sustainability, (c) devising suitable analytical methods, (d)
obtaining adequate data

assumes sustainability is a series of social states with particular characteristics

or conditions dened by sustainability criteria

activity, event, or technology is sustainable over the long-term taking account

of cumulative economic, environmental, and social impacts as well as intraand intergenerational equity

is the activity, event, or technology sustainable, yes or no?

to determine which actions are sustainable and which are not using broadbased, multidimensional criteria

conduct an all-encompassing appraisal to determine whether an activity or

event is or is not sustainable (dened in theory but not yet applied either exante or ex-post)

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Table 2. Comparison of Selected Assessment Tools According to Five Criteria for Holistic Sustainability Evaluation, adapted
from Gasparatos et al.32
assessment tools
criteria for holistic sustainability
evaluation

cost-benet analysis

index of sustainable economic welfare

(ISEW)

biophysical
models

composite sustainability
indices

integrateda

yes

yes

no

yes

predictiveb

yes

no

yes

yes

precautionaryc

no

no

some aspects

depends on choice of
methodology

no

no

depends on choice of
methodology

some aspects

some aspects

depends on choice of
methodology

participatoryd

depends on monetization
methodology

consideration of equity issuese

debatable

Integrate economic, environmental, social and institutional issues as well as consider their interdependencies. bConsider the consequences of
present actions well into the future. cAcknowledge the existence of uncertainties regarding the result of present actions and act with a precautionary
bias. dEngage the public. eConsider both intragenerational and intergenerational equity.

sustainable manner.14 In 2009, President B. H. Obama issued

Executive Order 13514, which encouraged sustainable
technologies and sustainable buildings in sustainable
locations as part of creating a clean energy economy, and
dened sustainability as creating and maintaining conditions,
under which humans and nature can exist in productive
harmony, that permit fullling the social, economic, and other
requirements of present and future generations.15
Although development of the RARM paradigm and
sustainability evaluation has, for the most part, proceeded
along distinct and unconnected tracks, there have been
scattered attempts to reconcile the two approaches,1622
including eorts to develop new methods and processes.2326
Nonetheless, there are few examples where combined methodologies have been used as decision-making tools in support of
regulatory choices.2730 In 2011, however, the National
Research Council (NRC) published Sustainability and the U.S.
EPA (known informally as the Green Book), which
recommended that EPA institutionalize sustainability and
adopt it as both a process and a goal to ensure long-term
human well-being.8 The NRC proposed a conceptual
framework for evaluating sustainability in the context of
EPAs mission and provided guidance about how the EPA
decision-making process rooted in the risk assessment/risk
management paradigm can be integrated into this new
sustainability framework....8 We believe the ultimate goal
should be an integrated assessment that combines expertise of
both sustainability and risk experts to incorporate necessary
information about anticipated economic, environmental, and
societal (including public health) eects into a systematic
analytic-deliberative process aimed at simultaneously protecting
ecological resources, safeguarding human health, and realizing
sustainable outcomes. In the following discussion we survey the
dierent tools available for sustainability evaluation and
examine conceptual frameworks that could be used to combine
sustainability and risk assessment into a cohesive and holistic
decision-making methodology.

attempt to make society more sustainable. The purpose of

sustainability evaluation according to Ness et al.24 is ... to
provide decision-makers with an evaluation of global to local
integrated nature-society systems in short and long term
perspectives.... Gasparatos and his colleagues32 suggest that a
consensus has emerged about the desirable attributes of
sustainability assessment, which include the following:
Integrated evaluationcombined assessment of eects
on environmental quality and public health, social wellbeing, economic welfare, and institutional issues as well
as their interdependencies.
Predictive capacityconsideration of the future eects of
present actions or inactions.
Conservative biasacknowledgment of uncertainties
about future consequences of present actions and
recognition of the concomitant need to proceed with
caution and prudent watchfulness.
Stakeholder participationmeaningful engagement of
stakeholders, including the general public.
Numerous frameworks for sustainability have been proposed,3436 and several reviews of sustainability assessment
methodologies have been published.17,24,32,3638 As noted by
Pope et al.,17 there are basically two dierent approaches to
sustainability evaluation: an integrated environmental assessment (IEA) that analyzes not only environmental eects but
also social and economic impacts with the aim of minimizing
unsustainability or attaining specic triple-bottom-line
objectives; and an integrated sustainability assessment (ISA)
that focuses on determining whether an action is demonstrably
sustainable based on established criteria.
The emphasis in IEAs is on reducing adverse eects on
sustainability by ensuring that combined consequences from an
activity or action are not unacceptably negative and will not
cause greater unsustainability in the future. The central focus of
ISAs, on the other hand, is on ensuring that activities and
actions make positive contributions toward sustainability. There
are two dierent kinds of ISAs that can be used to measure
progress toward stated objectives:17,32 baseline-oriented evaluations, which examine net improvement in sustainability over
current reference conditions, focusing on the question are
environmental, economic, and social impacts acceptable

TOOLS FOR SUSTAINABILITY EVALUATION

Sustainability evaluation has been dened by Devuyset et al.31
as ...a tool that can help decision-makers and policy-makers
decide which actions they should or should not take in an
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non-integrated (e.g., environmental pressure indicators)

-regional ow indicators (e.g., economy-wide material ow analysis, input-output energy analysis)
integrated (e.g., sustainable national income, ecological footprint, human development index)

life cycle assessment (e.g., guidelines and principles established by the international standards organization)
life cycle costing (e.g., life cycle cost assessment, full life cycle accounting)
product material ow analysis (e.g., material intensity analysis, substance ow analysis)
product energy analysis (e.g., process energy analysis, exergy analysis)

impact assessment (e.g., environmental impact analysis, strategic environmental assessment)

miscellaneous (e.g., conceptual modeling, risk analysis, vulnerability analysis, cost-benet analysis)

examples include contingent valuation, travel cost, hedonic pricing, avoided cost, replacement cost, and factor income

2. product-related assessment
either prospective and/or retrospective analysis with focus on the product-level ramications

3. integrated assessment
prospective analysis with focus on issues related to a proposed change in policy

4. monetary valuation (cross-cutting)

used when monetary valuations are needed as part of the tools listed above

type of evaluation tool

Table 3. Framework to Categorize Sustainability Evaluation Tools, Adapted from Ness et al.24

subcategories (examples)

compared to baseline sustainability?; and objectives-oriented

evaluations, which ascertain the extent to which a specic
management option achieves a stipulated level of sustainability,
focusing on the question are environmental, economic, and
social impacts consistent with or contributory to stated
sustainability goals and objectives? A comparison, adapted
from Pope et al.,17 of baseline-oriented and objectives-oriented
ISAs in relation to comprehensive sustainability evaluation is
provided in Table 1.
A review by Gasparatos et al.32 groups current sustainability
evaluation tools into three major categories:
Monetary tools, like contingent valuation methods, costbenet analysis, and indices of sustainable economic
welfare.
Biophysical models, such as emergy, exergy, and
ecological footprint.
Sustainability indicators and composite indices, as for
example indicators and indices that provide early warning
of economic, social, or environmental damage.
A summary is presented in Table 2 comparing two monetary
tools (cost-benet analysis and an index of sustainable
economic welfare), biophysical models, and composite
sustainability models according to whether they exhibit the
desirable characteristics of sustainability assessment discussed
earlier.
In general, the classication and evaluation of sustainability
indicators can be based on a subset of important measurement
dimensions, as summarized in a series of questions posed by
Singh et al.37
What characteristic(s) of sustainability does the indicator
measure?
What techniques and methods are used to construct the
index (e.g., quantitative/qualitative, subjective/objective,
cardinal/ordinal, unidimensional/multidimensional)?
Does the indicator look at the sustainability measure
across time and space and does it use an absolute or
relative scale?
Does the indicator measure sustainability in terms of
input (i.e., means) or output (i.e., ends)?
Is the indicator clear and simple in content, purpose,
method, comparative application, and focus?
Are necessary data available across time and space?
Is the indicator exible enough to allow for changes in
purpose, scope, and method and to facilitate comparative
applications?
A holistic framework for classifying sustainability assessment
tools developed by Ness et al.24 is summarized in Table 3. The
framework is based on the temporal (i.e., prospective versus
retrospective) and objective (i.e., product-level versus policy
change) focus of the tool and its integration of nature-society
systems (i.e., fusion of economic, environmental, and social
evaluations). Based on this schema there are three main
categories of sustainability assessment tools: (1) indicators and
indices, which can be subdivided into nonintegrated indicators,
regional ow indicators, and integrated indicators and indices;
(2) product-related tools, which include four main subcategorieslife-cycle assessment, life-cycle costing, product material
ow analysis, and product energy analysis; and (3) integrated
assessment tools, which include both (a) established methods
for environmental analysis that can be extended to sustainability, like multicriteria analysis, risk analysis, vulnerability
analysis, and cost-benet analysis and (b) impact assessment

1. indicators and/or indices

retrospective analysis with focus on issues related to a proposed change in policy

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ecologic resources and human health

formal process (including risk assessment guidelines) for estimating risk; statute-specic
policies for risk management

typically conducted under the auspices of a particular statute

fewer decisions are necessary because the scope is usually narrower

because the process typically occurs under the authority of a specic statute, only one
program/agency is usually involved

designated risk assessors (e.g., toxicologists, epidemiologists, exposure scientists) and risk
managers (e.g., politically appointed administrators and managers) within agencies

outcomes
considered

procedural
guidelines

statutory
relationship

no. decisions
needed

no. agencies
involved

assessors &
implementers

gradually expanding and sanctioned role in all aspects of the process; generally narrower
participation because of the specicity of risk-related questions

environmental pollutants and stressors (primarily chemicals but also nonchemical stressors
like the built environment and urban sprawl)

threats
addressed

stakeholder
involvement

what are the magnitude, probability, and uncertainty of estimated risks? which risks are
unacceptable? what should be done about unacceptable risks?

key questions

risk assessmentrisk management paradigm

statutory requirements; need to make regulatory decisions that are defensible in public and
in court

major drivers

process
attributes

generally inclusive throughout the process with broader participation because of the type of questions being
addressed

no designated cadre of sustainability assessors; need multi- and interdisciplinary teams, including social scientists,
physical scientists, engineers, economists, biomedical scientists, and public health specialists

because the process is likely to cut across diverse statutes, multiple programs and agencies will probably be involved

more decisions are necessary because the scope is usually broader

not required by statute, therefore, discretionary within statutory constraints

no consensus or ocial approach, but many dierent methods available (none, however, are veried or validated)

economic, social, and environmental eects, individually and jointly

economic (e.g., jobs), social (e.g., poverty), and environmental factors

which activities, substances, and technologies are unsustainable? how little harm is possible? how do we maximize
economic, environmental, and social benets simultaneously?

moral and ethical concerns about intergenerational equity; opportunities to reduce costs and increase environmental,
economic, and social benets for the current generation; concerns about environmental tipping points

sustainability evaluation

Table 4. Comparison of Key Attributes of the Risk AssessmentRisk Management Paradigm and Sustainability Evaluation in the Context of Regulatory Decision-Making,
adapted from the NRC.8

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which national progress can be measured, developing global

level indicators of planetary sustainability, and providing
individuals with indicators reecting their own progress and
providing positive incentives for further eorts.

methods, such as environmental impact assessment, strategic

environmental assessment, and sustainability impact assessment
that are integrated forecasting tools. Monetary valuation tools
(e.g., contingent valuation, hedonic pricing, avoided cost, factor
income) constitute a fourth, cross-cutting category that can be
used when monetary valuations are needed as part of indices,
product-related assessments, or integrated evaluation.24
Singh et al.37 developed a comprehensive overview of
composite indices that have been used for sustainability
evaluation, and identied 12 separate categories: (1)
innovation, knowledge, and technology indices (e.g., Summary
Innovation Index); (2) development indices (e.g., Human
Development index); (3) market- and economy-based indices
(e.g., Composite Leading Indicators); (4) ecosystem-based
indices (e.g., Sustainability Performance Index); (5) composite
sustainability performance indicators for industries (e.g.,
Composite Sustainable Development Index); (6) investment,
ratings, and asset management indices (e.g., Dow Jones
Sustainability Group Indices); (7) Product-Based Indices
(e.g., Life Cycle index); (8) sustainability indices for cities
(e.g., Urban Sustainability index); (9) environmental indices for
policies, nations, and regions (e.g., Environmental Sustainability
Index); (10) environmental indices for cities (e.g., EcoIndicator 99); (11) energy-based indices (e.g., Sustainability
Assessment Tool for Energy System); and (12) social and
quality of life indices (e.g., Physical Quality of Life Index). A
number of problems have been identied with current indices,
including (a) the fact that normalization and weighting of
indicators tend to be arbitrary; (b) there is often insucient
discussion of critical assumptions; (c) indices are largely
subjective despite the relative objectivity of the methods used;
(d) they often combine measures of ends and means and can
involve relatively complex procedures; and (e) they can be
misleading if poorly constructed and/or misinterpreted.37
Singh et al.37 remind us that sustainability is more than an
aggregation of the important issues, it is also about their
interlinkages and the dynamics developed in a system. This
overriding complexity is reected in the arguments by
Gasparatos et al.36 that using a single metric, such as a
composite index, biophysical model, or monetary evaluation
tool to assess sustainability is not justied because of
methodological imperfections and limitations. They observe
that individual metrics fail to address the requisite complex set
of varied issues over dierent time and spatial scales, lack
necessary involvement of diverse perspectives and areas of
expertise, and do not account for the fact that economies,
ecosystems, and societies are complex and adaptive systems.
According to Gasparatos et al.,36 Failure to describe these
systems in a holistic manner through the synthesis of their
dierent non-reducible and perfectly legitimate perspectives
amounts to reductionism. They contend that no single
methodology or metric currently provides a comprehensive
evaluation of sustainability, and that use of an assortment of
complementary approaches and measures is the most
promising way to make sustainability assessments more
compete and robust.36
In summary, there are currently viable tools for measuring
some elements of sustainability at dened geospatial scales, but
virtually all are limited to appraising unsustainable trends that
are subject to management actions. Consequently, they neither
define nor ensure sustainability. As stated by Dahl,38 The
challenges ahead include nding indicators of change in
dynamic systems, establishing sustainability targets towards

INTEGRATING SUSTAINABILITY EVALUATION

AND RISK ASSESSMENT
Within the domain of sustainability evaluation and in the
context of related analytical tools, conventional quantitative risk
assessment is typically categorized as a diagnostic instrument
for evaluating environmental impacts. It is regarded as a useful,
if limited technique for estimating the eect of hazardous
activities, substances, and technologies on environmental
quality and human health as input into risk management
decisions about which risks are unacceptable and what, if
anything, to do about them. Because the RARM paradigm is
tied closely to regulatory decision-making, it usually focuses
narrowly on hazards covered by statutory mandates, and
emphasizes adverse eects on human health and ecologic
resources, with secondary priority given to social welfare
eects.18 Sustainability assessment, in contrast, is not
necessarily tied to statutory requirements and is a much
broader eort encompassing evaluation of economic, social, and
environmental sustainability for the purpose of maximizing
benets across all three dimensions.9,16,17 Some of the key
dierences between the RARM paradigm and sustainability
evaluation are summarized in Table 4.8
The RARM paradigm was established in 1983 by a
groundbreaking report from the NRC, titled Risk Assessment in
the Federal Government: Managing the Process,1 also known as
the Red Book. Its origins can be traced to the important
regulatory issues of the 1970s and early 1980s, which focused
mainly on carcinogenic chemical pollutants in air and water
from heavy industry. The paradigm and its implementation
were inuenced strongly in the beginning by the prevailing
environmental protection ethos of that timenational
command-and-control strategies, technology-based regulations,
chemical-by-chemical pollution control and end-of-pipe
solutions. However, it soon became clear that the nature and
scope of the RARM paradigm needed to be modied as
newer, more complicated and expensive-to-solve problems
were identied, advancements in scientic knowledge improved
understanding about causal linkages between exposures and
eects, and enhanced analytical methods provided more and
better risk-related data.3,8,39 The evolution of the paradigm
since publication of the NRCs 1983 Red Book can be traced
through a series of public sector reports that oer critiques and
recommend modications (most of which have been adopted
in one form or another).
1983, Risk Assessment in the Federal Government:
Managing the Process by NRC.1
1994, Science and Judgment in Risk Assessment by
NRC.2
1996, Understanding Risk: Informing Decisions in a
Democratic Society by NRC.6
1997, Framework for Environmental Health Risk
Management by PCCRARM.7
2008, Public Participation in Environmental Assessment
and Decision Making by NRC.5
2009, Science and Decisions: Advancing Risk Assessment
by NRC.3
2011, Sustainability and the U.S. EPA by NRC8.
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Table 5. Comparison of Four Ways to Combine Risk and Sustainability Assessments in Regulatory Decision-Making
brief description

references

1. independent assessments of risk

and sustainability

relations between assessments

risk and sustainability are treated as separate analytic domains, and are
evaluated separately with results from both used in making decisions

represents the status quo, with risk analyzed

independently and sustainability, if it is analyzed
at all, done separately8

2. sustainability is incorporated into

the risk assessmentrisk
management paradigm

risk is the overarching conceptual construct and sustainability is

evaluated within this context

relatively few, case-specic examples16,20,27,29,30,46

3. risk is incorporated into the

sustainability paradigm

sustainability is the overarching conceptual construct and risk is

assessed and managed with this context

numerous examples8,17,19,24,32,37,4749

4. integrated analysis of risk and

sustainability

risk and sustainability are merged into a single analytic domain and
appraised using an integrated diagnostic approach that produces a
distinct, amalgamated result

represents a theoretical ideal, where both risk and

sustainability are assessed in one seamless, unied
procedure45

dening the relative roles of both approaches is a good starting

point for answering this question.
As summarized in Table 5, there are fundamentally four ways
to reconceptualize the roles of the RARM paradigm and
sustainability evaluation in the context of regulatory decisionmaking.45 First, risk and sustainability can be thought of as
independent but complementary and overlapping analytic
domains, wherein risk and sustainability assessment are
conducted separately and results of both are used in making
decisions. Second, risk can be viewed as the overarching
conceptual construct within which sustainability is evaluated,
which implies treating sustainability evaluation as a subsidiary
feature of the RARM paradigm. Third, sustainability can be
considered the overarching conceptual construct, wherein the
RARM paradigm is incorporated as a subsidiary feature of
sustainability evaluation. And fourth, sustainability and risk
could be merged into a single hybrid, analytical domain that
does not subordinate one to the other, and that entails an
integrated diagnostic approach producing a distinct, amalgamated result.45
Independent risk assessments are routinely conducted to
organize and analyze scientic information related to
regulatory-relevant eects on the environment and public
health. Economic and social factors are considered separately
(and usually informally) as part of the subsequent risk
management phase. Structured sustainability evaluations are
rarely, if ever, conducted in the context of risk management
decisions for regulatory purposes, and historically have not
been coordinated with or connected to relevant risk assessments. For option 1 (independent analyses of risk and of
sustainability) to be both practical and benecial, it will
ultimately be necessary to coordinate assessments of risk and
sustainability so that results are complementary and congruent.
This will require a mechanism to integrate the results of these
independent analyses (such as the principles of sustainability),
an all-encompassing evaluation strategy, a harmonized analysis
plan, and coherent arrangements for communicating results to
decision makers and stakeholders in a timely and understandable way. To our knowledge, this has not yet been
accomplished, or even attempted.
Option 2 (incorporating sustainability into the RARM
paradigm) would involve dening the key issues in terms of
risk, framing critical questions in terms like risk, vulnerability
to risk, and risk prevention or reduction, and obtaining
concurrence from all relevant risk takers, risk bearers, and risk
regulators. The RARM paradigm would have to expand to
include multidimensional, holistic assessments that explicitly

From these reports it is possible to discern four major trends

in the evolution of the RARM paradigm over the past three
decades. First, there is general agreement that it is important at
the outset of the process to develop and formalize a shared
understanding of the context, formulation, and scope of the
problem being addressed, including concurrence among
participants regarding a suitable risk assessment approach.3,8
Second, the need for meaningful involvement of stakeholders,
including members of aected communities, in all aspects of
the process is now widely accepted as an intrinsic part of
assessing and managing risk.5,7 Third, there is formal
recognition of the fact that socioeconomically and politically
disadvantaged communities, many of whom are ethnic and
racial minorities, are likely to be more vulnerable to the adverse
eects of pollution because they are both more exposed and
more susceptible than the general population.3,3941 And
fourth, a growing consensus has emerged among experts and
the public that the domain of risk assessmentmanagement
must expand beyond a narrow focus on individual chemicals
from single sources or source categories to encompass a
broader perspective that includes analysis of combined eects
from exposures to multiple chemical and nonchemical stressors
released by a diverse array of sources.3,39,4144
The aggregate impact of these trends has been to make the
RARM management paradigm more comprehensive and
participatory,3,5,7 and to expand the scope of analysis to include
(a) both intrinsic (e.g., genetics, gender, age) and acquired
(e.g., quality of life and lifestyle attributes) susceptibility
factors,3,39 (b) both chemical (e.g., benzene, ozone) and
nonchemical (e.g., psychosocial stress) stressors,3,39,44 (c) social
welfare eects (e.g., inuence of odors and anxiety about
pollution on quality of life), as well as (d) eects on human
health and ecosystems.3,8,39 At the same time, the importance
of appraising environmental, economic, and social impacts of
human activities has become widely accepted, and the
practicality of sustainability evaluation has been enhanced by
development of advanced tools to deal with complex, crosscutting issues.1724 Given the conuence of these two
developments, the key question becomes: How should the
U.S. EPA and other government entities merge the RARM
paradigm with sustainability evaluation to ensure holistic
decision-making that is workable within data limitations,
prudent in terms of balancing environmental, economic, and
social values, and timely in the sense of providing answers to
critical questions within a reasonable period? A survey of the
conceptual approaches and theoretical frameworks available for
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The fourth option (integrated analysis of risk and

sustainability) represents a theoretical model for what might
someday be possible if obstacles such as data deciencies, lack
of mechanistic understanding, and a shortage of methods for
cumulative eects assessment can be overcome. Ideally,
assessment of risk and sustainability would be merged into
one analytic domain and evaluated using an integrated
diagnostic approach that produces a distinct, amalgamated
result. The ultimate goal (some would say holy grail) is to be
able to evaluate both risk and sustainability in one seamless,
unied procedure.45

involve evaluation of environmental, economic, and social end

points, along with equity-related issues.46 To date, risk
assessment has been used as a tool to evaluate sustainability
issues primarily in the context of specic, well-dened
problems; including, sustainable development in the Australian
coal industry,29 sustainability of Beluga whale harvesting,27
sustainable urban water systems,30 and sustainability of urban
centers.20 In contrast to conventional sustainability appraisal
where the focus is on assessing both negative and positive
impacts, the emphasis from a risk standpoint tends to be on
avoiding negative outcomes (e.g., baseline-oriented) or
determining whether minimum threshold values for sustainability have been met (e.g., objectives-oriented).
The most intuitively appealing approach is probably option 3
(incorporating the RARM paradigm into sustainability
assessment) because sustainability is such a broad concept
that it seems natural to fold-in the historically much narrower
RARM paradigm as a mechanism to measure environmental
eects, and rely on other analytic tools to appraise social,
economic, and equity-related factors.8,17,24,32,37 To be successfully implemented in a regulatory setting, this approach would
again require consensus among risk takers, risk bearers, and risk
regulators. There are numerous examples wherein risk
assessment is described and/or used as a specic instrument
for measuring environmental impacts as part of a more
comprehensive sustainability evaluation framework, including
estimation of energy production from biomass,49 analysis of
energy development projects,48 and evaluation of consumer
electronic products.47 Recently, the NRC8 advocated using the
concept of sustainability both as a goal and a process in
regulatory decision-making, and recommended that EPA adopt
a comprehensive decision-making framework to evaluate
sustainability, and develop suitable tools to further this
overarching goal.
In the NRCs schema, the RARM paradigm is embedded in
an overall framework for making decisions about sustainability.
According to the NRC, the sustainability assessment and
management step in the proposed sustainability decision
framework can be viewed as representing the risk paradigm
expanded and adapted to address sustainability goals.8 In the
NRCs view, the problem formulation and scoping (Phase I)
of the RARM paradigm would embody consideration of
options for improvements in economic, environmental, and
social attributes, along with evaluation of options to minimize
human health risk. The planning and conducting step (Phase
II) of the RARM paradigm would involve not just
conventional risk analysis, but also assessment of critical
economic, environmental, and social characteristics of identied
control options in order to create a sustainability comparison.
And risk management (Phase III) would entail consideration of
relevant social norms and values, ethical and moral issues,
economic costs and benets, legal constraints, political realities,
and technical and scientic information necessary to select a
sustainable course of action, instead of focusing exclusively on
how to minimize risks to human health and environmental
quality as is presently the case with the conventional RARM
paradigm. From the NRCs perspective,8 the RARM paradigm
is part of a toolbox for sustainability appraisal, with includes
other methods, such as life-cycle assessment, benet-cost
analysis, ecosystem services valuation, integrated assessment
models, sustainability impact assessment, environmental justice
analysis, and present/future scenario development.

CONCLUDING THOUGHTS
The terms risk and sustainability are unavoidably
ambiguous and amenable to interpretation, so it is not
surprising that debates about denitions and interpretations
are ongoing.16,17,3238,5052 Nor is it unexpected that attempts
to assess risk and sustainability can quickly turn into ideological
and political arguments over what kind of society we want to
live in and how best to make progress toward laudable
goals.1416,36,51,52 But discord among stakeholders can obscure
the fact that conceptualizations of risk and sustainability are
intimately connected, and that one cannot be understood
without the other.52 Smith52 identies four important areas of
commonality between risk and sustainability.
Sustainability is concerned with the future and decisions
about the future, which necessarily involves uncertainty
and concomitant risk.
Risk management and sustainability share mutual
relevance as practical alternatives for dealing with the
same kinds of problems.
Lay people tend to evaluate risk in a more holistic
manner than expert risk assessors by informally and
intuitively taking account of social, economic, and
environmental impacts of decisions.
Both conceptualizations are subject to the eects of risk
perception and social amplication.
Mounting evidence suggests that the future of humanity may
depend on our collective willingness and capacity to correctly
appraise both risk and sustainability in a judicious manner. The
reality, however, is that sustainability evaluation is at an
adolescent stage of development,48 risk assessmentrisk
management is approaching middle-age,3 and joint assessment
of risk and sustainability is still in its infancy.8 To move forward,
it is necessary that we make an explicit choice about whether to
(a) keep risk and sustainability assessments separate and then
combine results in the nal decision-making process, (b)
incorporate sustainability into the RARM paradigm, (c)
incorporate the RARM paradigm into sustainability evaluation, or (d) merge assessment of sustainability and risk into one
integrated analytical procedure. At the same time, we need to
acknowledge that this choice has ramications for both the
process and the product of regulatory decision-making.
On the positive side, we nd that dierent denitions of
sustainability are more or less adaptable to the RARM
paradigm and can interact with risk-based approaches in
distinctive ways.45 Similarly, dierent structuring of the RA
RM paradigm can make it more or less compatible with
sustainability evaluation. As cumulative notions of risk become
more prominent, the kinds of data necessary to complete an
inclusive risk assessment begin to overlap with the data needed
for a sustainability assessment. Ultimately, as data needs
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Environmental Science & Technology

Policy Analysis

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converge, the analytical features that separate the assessments

can be expected to share more procedures in common, and
existing barriers to integration will become progressively
smaller. In the meantime, we suggest a careful weighing of
the choices delineated in Table 5 with a bias in favor of holistic
assessments aimed at achieving acceptable risks in the context
of a sustainable future.

AUTHOR INFORMATION

Corresponding Author

*Phone: +1-956-882-5164; fax: +1-956-882-5152; e-mail: ken.

sexton@uth.tmc.edu.
Notes

The authors declare no competing nancial interest.

ACKNOWLEDGMENTS
Partial funding was provided by the U.S. Environmental
Protection Agency under a contract to The Scientic
Consulting Group, Inc. The views expressed are those of the
authors and do not necessarily represent Agency views or
policy.

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