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From Safety to Risk: The Cold War Contexts of American Environmental Policy

Published online by Cambridge University Press:  15 December 2016

Linda Nash*
Affiliation:
University of Washington

Abstract

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Articles
Copyright
Copyright © Donald Critchlow and Cambridge University Press 2017 

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References

NOTES

1. Beck, Ulrich, Risk Society: Towards a New Modernity (London, 1992).Google Scholar

2. For example, Jasanoff, Sheila, The Fifth Branch: Science Advisers as Policymakers (Cambridge, Mass., 1994)Google Scholar; Wynne, Brian, “Creating Public Alienation: Expert Cultures of Risk and Ethics on GMOs,” Science as Culture 10, no. 4 (December 2001): 445–81;CrossRefGoogle Scholar Heise, Ursula K., Sense of Place and Sense of Planet: The Environmental Imagination of the Global (Oxford, 2008), 115–59Google Scholar; Krimsky, Sheldon and Golding, Dominic, eds., Social Theories of Risk (Westport, Conn., 1992)Google Scholar; Lupton, Deborah, Risk (New York, 1999)Google Scholar.

3. Important exceptions to this generalization include Robert Castel, “From Dangerousness to Risk,” in The Foucault Effect: Studies in Governmentality, ed. Graham Burchell, Collin Gordon, and Peter Miller (Chicago, 1991), 281–98 (on risk and the construction of the psychiatric subject); Winner, Langdon, The Whale and the Reactor: A Search for Limits in an Age of High Technology (Chicago, 1986), 138–54;Google Scholar Luhmann, Niklas, Risk: A Sociological Theory (New York, 1993);Google Scholar Boudia, Soraya, “Managing Science and Political Uncertainty: Environmental Risk Assessment in Historical Perspective,” in Powerless Science? Science and Politics in a Toxic World, ed. Boudia, Soraya and Jas, Nathalie, vol. 2 (New York: 2014), 95113.Google Scholar For ahistoric uses of risk, see Mohun, Arwen, Risk: Negotiating Safety in American Society (Baltimore, 2013)Google Scholar; Douglas, Mary and Wildavsky, Aaron B., Risk and Culture: An Essay on the Selection of Technical and Environmental Dangers (Berkeley, 1982)Google Scholar. For important historical treatments, see Boyd, William, “Genealogies of Risk: Searching for Safety, 1930s–1970s,” Ecology Law Quarterly 39, no. 4 (November 2012): 895987Google Scholar; Vogel, Sarah A., Is It Safe?, BPA and the Struggle to Define the Safety of Chemicals (Berkeley, 2013)Google Scholar; Carlisle, Rodney P., “Probabilistic Risk Assessment in Nuclear Reactors: Engineering Success, Public Relations Failure,” Technology and Culture 38, no. 4 (1997): 920–41;CrossRefGoogle Scholar Joseph Boland, “The Cold War Legacy of Regulatory Risk Analysis: The Atomic Energy Commission and Radiation Safety” (Ph.D. diss., University of Oregon, 2002); Andrews, Richard N. L., “Risk-Based Decision Making: Policy, Science, and Politics,” in Environmental Policy: New Directions for the Twenty-First Century (Washington D.C., 2006), 215–38Google Scholar. For a focus on industry’s role, see Rosner, Gerald David and Markowitz, Gerald, “Industry Challenges to the Principle of Prevention in Public Health: The Precautionary Principle in Historical Perspective,” Public Health Reports 117, no. 6 (2002): 501–12Google Scholar; Davis, Devra, The Secret History of the War on Cancer, Reprint edition (New York, 2009)Google Scholar.

4. Recently, Jacob Hamblin has addressed the role of systems analysis and military planning in creating a discourse of environmental catatastrophism. Jacob Darwin Hamblin, Arming Mother Nature: The Birth of Catastrophic Environmentalism (New York, 2013).

5. Suzanne Rebecca White, “Chemistry and Controversy: Regulating the Use of Chemicals in Foods, 1883–1959” (Ph.D. diss., Emory University, 1994), 1–45; Petrick, Gabriella M., “Purity as Life: H.J. Heinz, Religious Sentiment, and the Beginning of the Industrial Diet,” History and Technology 27, no. 1 (2011): 3764;CrossRefGoogle Scholar Nash, Linda, “Purity and Danger: Historical Reflections on the Regulation of Environmental Pollutants,” Environmental History 13, no. 4 (October 2008): 651–58.Google Scholar The 1906 law did not grant Wiley authority to regulate pesticides (which were considered poisonous but necessary to agriculture), only processed foods. That set up divergent pathways for chemicals on produce versus those in processed foods; the former would be treated much more leniently. See Whorton, James C., Before Silent Spring: Pesticides and Public Health in Pre-DDT America (Princeton, 1975)Google Scholar.

6. Nash, Linda, Inescapable Ecologies: A History of Environment, Disease, and Knowledge (Berkeley, 2006), 11–13, 82–90Google Scholar; Worboys, Michael, Spreading Germs: Disease Theories and Medical Practice in Britain, 1865–1900 (Cambridge, 2000);Google Scholar Tomes, Nancy, The Gospel of Germs: Men, Women, and the Microbe in American Life (Cambridge, Mass., 1998);Google Scholar White, “Chemistry and Controversy,” 1–45; Tarr, Joel A. and Gurian, Patrick L., “The Origin of Federal Drinking Water Quality Standards,” Proceedings of the ICE–Engineering History and Heritage 164, no. 1 (February 2011): 1726.Google Scholar

7. In 1927, the USDA’s Bureau of Chemistry would become the Food and Drug Administration, and in 1940 it would move from the Department of Agriculture to the new Federal Security Agency; in 1953, it was moved into the Department of Health, Education, and Welfare. John P. Swann, “FDA’s Origin,” http://www.fda.gov/AboutFDA/WhatWeDo/History/Origin/ucm124403.htm(accessed 1 December 2014). The 1938 law acknowledged that a few nonnutritive additives could not be avoided, and it charged the FDA with setting appropriate tolerances for those substances. On the increase in chemicals, see White, “Chemistry and Controversy,” 230–21; Bert J. Vos et al., “Oral History of the U.S. Food and Drug Administration-Pharmacologists” (U.S. Food and Drug Administration, 20 June 1980), National Library of Medicine (NLM), http://www.fda.gov/downloads/AboutFDA/WhatWeDo/History/OralHistories/SelectedOralHistoryTranscripts/UCM265869.pdf (accessed 24 March 2012).

8. Orren, Karen, Belated Feudalism: Labor, the Law, and Liberal Development in the United States (New York, 1991)Google Scholar; Rogers, Donald W., Making Capitalism Safe: Work Safety and Health Regulation in America, 1880–1940 (Urbana, Ill., 2009), 1130Google Scholar.

9. Sturdy, Steve, “Biology as Social Theory: John Scott Haldane and Physiological Regulation,” British Journal of the History of Science 21 (1988): 315–40;CrossRefGoogle Scholar Sellers, Christopher C., Hazards of the Job: From Industrial Disease to Environmental Health Science (Chapel Hill, 1997), 175–83Google Scholar; Derickson, Alan, “Physiological Science and Scientific Management in the Progressive Era: Frederic S. Lee and the Committee on Industrial Fatigue,” Business History Review 68 (1994): 483514Google Scholar; Gillespie, Richard, “Industrial Fatigue and the Discipline of Physiology,” in Physiology in the American Context, 1850–1940, ed. Geison, Gerald L. (Bethesda, Md., 1987), 237–62.Google Scholar

10. Sellers, Hazards of the Job, 175–83; Nash, “Purity and Danger.”

11. A. J. Lehman, et al. “Procedures for the Appraisal of the Toxicity of Chemicals in Foods,” Food, Drug, and Cosmetic Law J. (1949): 412–34; Lehman, A. J. and Garth Fitzhugh, O., “100-fold Margin of Safety,” Quarterly Bulletin of the Association of Food and Drug Officials of the U.S. 18 (1954): 3335;Google Scholar On the FDA’s conservatism in this period, see White, W. B., “The Addition of Chemicals to Foods,” Food-Drug-Cosmetic Law Quarterly 2 (1947): 475–89;Google Scholar White, Chemistry and Controversy, 230–36; Langston, Nancy, Toxic Bodies: Hormone Disruptors and the Legacy of DES (New Haven, 2010), 3544.Google Scholar

12. Vogel, Is It Safe?, 19–38; White, “Chemistry and Controversy,” 309–61.

13. For a detailed accounting of the complicated chain of events at the FDA during this period, see Vogel, Is It Safe?, 39–63. FDA had, in fact, banned a few suspected carcinogens based on concerns over safety years prior to the passage of the Delaney Clause. Peter Barton Hutt, “History of the Food and Drug Administration: A Brief History of Risk Assessment” (U.S. Food and Drug Administration, 1 November 2000), 8, NLM, http://www.fda.gov/downloads/AboutFDA/WhatWeDo/History/OralHistories/SelectedOralHistoryTranscripts/UCM288761.pdf (accessed 5 March 2012).

14. “Risk” was not mentioned in the final statute, nor was it discussed as a possible framework in the hearings that preceded its adoption. U.S. Senate, Committee on Public Works, Subcommittee on Air and Water Pollution, Air Pollution—1970: Hearings, Parts 1–4 (1970), 91st Cong., 2nd sess.

15. Imsland, Lori C., “Comment: How Much Would You Pay for Clean Air? The Role of Cost/Benefit Analysis in Setting NAAQS,” Missouri Environmental Law & Policy Review 9 (2002): 4452;Google Scholar Amy Quandt, “American Trucking Associations, Inc. v. United States Environmental Protection Agency: A Speed-Bump Along the Highway of Judicial Deference to Agency Determinations,” Villanova Environmental Law Journal 11 (2000): 425–60. On the safety approach of early environmental legislation, see also Boyd, “Genealogies of Risk.” The Federal Environmental Pesticide Control Act, passed in 1972, did use the term “risk,” which proscribed pesticides that “caused unreasonable risk to man or the environment, taking into account the economic, social, and environmental costs and benefits.” Pesticides, as mentioned above, had been a special case since they were regarded as both necessary and poisonous and thus had always been subject to a loose sort of cost-benefit consideration since the first attempts at regulation in the 1910s. See John Wargo, Our Children’s Toxic Legacy: How Science and Law Fail to Protect Us from Pesticides (New Haven, 1996), 89; Whorton, Before Silent Spring. FDA had also introduced the term “risk” into its proposed “sensitivity-of-method” regulations (1973) on carcinogenic animal feeds, but initially these regulations did not reflect the arrival of a risk-based regulatory approach; they were merely intended to encourage industry to adopt better testing protocols. On this, see Schneiderman, Marvin A. and Mantel, Nathan, “The Delaney Clause and a Scheme for Rewarding Good Experimentation,” Preventive Medicine 2, no. 1 (March 1973): 165–70.CrossRefGoogle Scholar

16. Vogel, Is It Safe?, 58–59; Boyd, “Genealogies of Risk”; Rachel Carson, Silent Spring (Boston, 1962); President’s Science Advisory Committee, Restoring the Quality of Our Environment (Washington D.C., 1965), 16. Additionally, national delegates to the first United Nations Conference on the Environment, held in Stockholm in 1972, overwhelmingly approved a resolution confirming every person’s right to live in a quality environment. “Declaration of the United Nations Conference on the Human Environment,” United Nations Environment Program, www.unep.org. On fluoridation, see Christopher Sellers, “The Artificial Nature of Fluoridated Water: Between Nations, Knowledge, and Material Flows,” Osiris 19 (2004): 182–200; Gretchen Reilly, “‘This Poisoning of Our Drinking Water’: The American Fluoridation Controversy in Historical Context, 1950—1990” (Ph.D. diss., George Washington University, 2001).

17. A crucial study was published in 1950 that strongly indicated a link between radiation exposure and leukemia. March, H. C., “Leukemia in Radiologists in a 20-Year Period,” Am. J Med. Sci. 220 (1950): 282–86.CrossRefGoogle Scholar On role of scientists, see Boland, “Cold War Legacy,” 71–75; Karl Z. Morgan and Ken M. Peterson, The Angry Genie: One Man’s Walk Through the Nuclear Age (Norman, Okla., 1999), esp. 115–18.

18. Stone, Robert, “The Concept of a Maximum Permissible Exposure,” Radiology 58 (1952): 639–60;CrossRefGoogle Scholar National Committee for Radiation Protection, Permissible Dose from External Sources of Ionizing Radiation, National Bureau of Standards Handbook 59 (Washington, D.C., 1954), 20–22; Walker, J. Samuel, Permissible Dose: A History of Radiation Protection in the Twentieth Century (Berkeley, 2000), 1012Google Scholar; Boland, “Cold War Legacy,” 496–617; Gilbert Franklin Whittemore, “The National Committee on Radiation Protection, 1928–1960: From Professional Guidelines to Government Regulation” (Ph.D. diss., Harvard University, 1987), 309–15.

19. Boland, “Cold War Legacy,” 623–29; Hamblin, Jacob Darwin, “‘A Dispassionate and Objective Effort’: Negotiating the First Study on the Biological Effects of Atomic Radiation,” Journal of the History of Biology 40, no. 1 (Spring 2007): 147–77;CrossRefGoogle Scholar Whittemore, “National Committee on Radiation Protection,” 322–59, 515–16 (on compromises with production goals); Kate Brown, Plutopia: Nuclear Families, Atomic Cities, and the Great Soviet and American Plutonium Disasters (Oxford, 2013), esp. 165–71.

20. On RAND and its methods, see Amadae, S. M., Rationalizing Capitalist Democracy: The Cold War Origins of Rational Choice Liberalism (Chicago, 2003), 2786Google Scholar; Kuklick, Bruce, Blind Oracles: Intellectuals and War from Kennan to Kissinger (Princeton, 2006)Google Scholar; David Raymond Jardini, “Out of the Blue Yonder: The RAND Corporation’s Diversification into Social Welfare Research, 1946–1968” (Ph.D. diss., Carnegie Mellon University, 1996); Stephanie Caroline Young, “Power and the Purse: Defense Budgeting and American Politics, 1947–1972” (Ph.D. diss., University of California, Berkeley, 2009); Hunter Heyck, Age of System: Understanding the Development of Modern Social Science (Baltimore, 2015), 3 (quote).

21. John L. Umlauf, “Case History/Minuteman/For Weapon System Safety”; Richard L. Reeb, “Air Force Management of the System Safety Program”; Kazuo Kanda, “Concept of Safety Mathematics,” in Systems Safety Symposium: Proceedings (Seattle, 1965), n.p.

22. A. B. Mearns, “Fault Tree Analysis: The Study of Unlikely Events in Complex Systems,” in Systems Safety Symposium, n.p.; Thomas P. Hughes, Rescuing Prometheus (New York: Pantheon, 1998); Carlisle, Rodney P., “Probabilistic Risk Assessment in Nuclear Reactors: Engineering Success, Public Relations Failure,” Technology and Culture 38, no. 4 (1997): 920–41;CrossRefGoogle Scholar Mohammad Modarres and Inn Seock Kim, “Deterministic and Probabilistic Safety Analysis,” in Handbook of Nuclear Engineering, ed. Dan Gabriel Cacuci (Boston, 2010), 1739–1812.

23. Reeb, “Air Force Management,” n.p.

24. U.S. Atomic Energy Commission (AEC), “Theoretical Possibilities and Consequences of Major Accidents in Large Nuclear Power Plants,” WASH-740 (Washington, D.C., 1957); Clarfield, Gerard H., Nuclear America : Military and Civilian Nuclear Power in the United States, 1940–1980 (New York, 1984), 196–97Google Scholar; Mazuzan, George T. and Walker, J. Samuel, Controlling the Atom: The Beginnings of Nuclear Regulation, 1946–1962 (Berkeley, 1985), 200208Google Scholar; Wellock, Thomas R., Critical Masses : Opposition to Nuclear Power in California, 1958–1978 (Madison, 1998).Google Scholar

25. Starr, Chauncey, “Radiation in Perspective,” Nuclear Safety 5 (1964): 325–35;Google Scholar “Chauncey Starr, 95; Physicist, Proponent of Nuclear Energy,” Washington Post, 21 April 2007; Sowby, F. D., “Radiation and Other Risks,” Health Physics 11, no. 9 (1965): 879–87;CrossRefGoogle Scholar Farmer, Frank R., “Reactor Safety and Siting: A Proposed Risk Criterion,” Nuclear Safety 8 (1967): 539–48.Google Scholar See also Sterner, J. H., “Atomic Energy for Society and the Balance between Hazard and Gain,” Nuclear Safety 6 (1964): 143–45.Google Scholar

26. Starr, Chauncey, “Social Benefit versus Technological Risk,” Science 165 (19 September 1969): 1232–38Google Scholar; Starr, “Plenary: Twenty-Year Retrospective on 1969 Science Paper, ‘Social Benefit versus Technological Risk,’” in Risk Analysis: Prospects and Opportunities, ed. Constantine Zervos et al. (New York, 1988), 1–6.

27. For critique, see Goodman, D., “Ideology and Ecological Irrationality,” BioScience 20 (1970): 1247–52Google Scholar. U.S. Nuclear Regulatory Commission, “Reactor Safety Study: An Assessment of Accident Risks in U.S. Commercial Power Plants, NUREG-75/014 (WASH-1400) (Washington, D.C., 1975); Walker, J. Samuel, A Short History of Nuclear Regulation, 1946–1999 (Darby, Pa., 2001), 4849.Google Scholar Arthur Schlesinger, the chairman of the AEC at the time the study was commissioned, was a former RAND analyst. See Carlisle, “Probabilistic Risk Assessment,” 932–35. The regulatory functions of the AEC were shifted to the newly formed Nuclear Regulatory Commission in 1975. Walker, Short History, 44–45.

28. Rowe, William D., An Anatomy of Risk (New York, 1977)Google Scholar; “They Bet Your Life,” Washington Post, 18 November 1979.

29. National Academy of Sciences, Committee on Science and Public Policy (COSPUP), Risks Associated with Nuclear Power : A Critical Review of the Literature : Summary and Synthesis Chapter (Washington, D.C., 1979); Lowrance, William W., Of Acceptable Risk: Science and the Determination of Safety (Los Altos, Calif., 1976), 109Google Scholar. Upon completing his fellowship, Lowrance took up a temporary research position at Harvard’s Program on Science and International Affairs, in which Harvey Brooks was a key faculty member. The NAS also sponsored key early conferences on risk and public policy, and some of its staff members would help found the Society for Risk Analysis. Geiger, Roger L., Research and Relevant Knowledge: American Research Universities Since World War II (Oxford, 1993), 170–73Google Scholar; Cohen, Robert S., The Natural Sciences and the Social Sciences: Some Critical and Historical Perspectives (New York: 2013), 380–86Google Scholar; Paul Deisler Jr. and Richard C. Schwing, “History of the Society for Risk Analysis Through the Year 2000” (Society for Risk Analysis, 2003), http://www.sra.org/sites/default/files/pdf/history/SRA20YearHistory.pdf (accessed 19 August 2015); Boudia, “Managing Science and Political Uncertainty.”

30. Jardini, “Out of the Blue Yonder,” 190–343; Young, “Power and the Purse,” 201–310; Light, Jennifer S., From Warfare to Welfare: Defense Intellectuals and Urban Problems in Cold War America (Baltimore, 2005)Google Scholar.

31. On critiques, see Kuklick, Blind Oracles, 151–52; Young, Power of the Purse, 249–63. For influential contemporary critiques, see Wildavsky, Aaron, “The Political Economy of Efficiency: Cost-Benefit Analysis, Systems Analysis, and Program Budgeting,” Public Administration Review 26, no. 4 (December 1966): 292310Google Scholar; Hoos, Ida R., Systems Analysis in Public Policy: A Critique (Berkeley, 1972)Google Scholar; Tribe, Laurence H., “Policy Science: Analysis or Ideology?” Philosophy & Public Affairs 2, no. 1 (1 October 1972): 66110Google Scholar. On RAND’s move into domestic policy, see Levien, Roger E., “RAND, IIASA, and the Conduct of Systems Analysis,” in Systems, Experts, and Computers: The Systems Approach in Management and Engineering, World War II and After, ed. Hughes, A. C. and Hughes, T. P. (Cambridge, Mass., 2000), 433–62Google Scholar; Jardini, “Out of the Blue Yonder,” 304–424. For reformulation, see C. T. Whitehead, “Uses and Limitations of Systems Analysis” (1967), http://www.rand.org/pubs/papers/P3683.html (accessed 3 February 2015).

32. A key aspect of Raiffa’s work was his reliance on Bayesian approaches and subjective probabilities. These were also hallmarks of much of the RAND work in systems analysis. Luce, R. Duncan and Raiffa, Howard, Games and Decisions: Introduction and Critical Survey (New York, 1957)Google Scholar; Howard Raiffa, “Decision Analysis: A Personal Account of How It Got Started and Evolved,” in Advances in Decision Analysis: From Foundations to Applications, ed. Ward Edwards, Ralph F. Miles, and Winterfedlt (New York, 2007), 57–70; Fienberg, Stephen E., “The Early Statistical Years: 1947–1967: A Conversation with Howard Raiffa,” Statistical Science 23, no. 1 (2008): 136–49;CrossRefGoogle Scholar Raiffa, Howard, “My 1969 RAND Report,” Journal of Multi-Criteria Decision Analysis 14, no. 4–6 (2006): 159–60.CrossRefGoogle Scholar

33. Amadee, Rationalizing Capitalist Democracy, 71; Heyck, Age of System, 137; E. S. Quade, Analysis for Public Decisions (New York, 1975); Jenn, Werner, “From Policy Analysis to Political Management? An Outside Look at Pubic Policy Training in the U.S.,” in Social Sciences and Modern States: National Experiences and Theoretical Crossroads, ed. Wagner, Peter et al. (Cambridge, 1991), 110–30Google Scholar; Dror, Yehezkel, “Prolegomena to Policy Sciences,” Policy Sciences 1, no. 1 (Spring 1970): 135–50Google Scholar; Tadao Miyakawa, ed., The Science of Public Policy: Evolution of Policy Sciences (New York, 1999); “Harvard Kennedy School Oral History: Thomas Schelling,” 29 January 2014, http://www.youtube.com/watch?v=fujQaAgqgxQ (accessed 3 February 2015); Richard Magat, The Ford Foundation at Work: Philanthropic Choices, Methods and Styles (New York, 1979), 101–3; Kuklick, Blind Oracles, 163. Just a few years later, Harvard’s School of Public Health under Dean Howard Hiatt would also embrace “health economics”—a subdiscipline developed at RAND. Robin Marantz Henig, The People’s Health: A Memoir of Public Health and Its Evolution at Harvard (Washington, D.C., 1996), 184–85; Richard Norton Smith, The Harvard Century: The Making of a University to a Nation (New York, 1986), 322–26. Although beyond the scope of this essay, the role of the Ford Foundation in pushing these techniques forward was crucial. Ford funded not only the new schools of public policy, but also RAND and other institutions involved in environmental policy, notably Resources for the Future.

34. Jenn, “From Policy Analysis to Political Management?”; Schultz, Politics and Economics of Public Spending; Howard Raiffa, Decision Analysis; Introductory Lectures on Choices Under Uncertainty (Reading, Mass., 1968); Howard Raiffa, Memoir: Analytical Roots of a Decision Scientist (n.p.: CreateSpace Independent Publishing Platform, 2011), 141; Paul Erickson et al., How Reason Almost Lost Its Mind: The Strange Career of Cold War Rationality (Chicago, 2013).

35. Alter, Jonathan, “Harvard vs. Democracy,” Washington Monthly 15 (1983): 3239Google Scholar; National Research Council, Committee on Risk and Decision Making (CORADM), Perspectives on Risk and Decision Making (Washington, D.C., 1982), http://www.ncbi.nlm.nih.gov/books/NBK218911/ (accessed 3 February 2015). On centralization, see Whitehead, “Uses and Limitations,” 104; Nelson, Robert H., “The Office of Policy Analysis in the Department of the Interior,” Journal of Policy Analysis and Management 8, no. 3 (1 July 1989): 395410Google Scholar.

36. “In Memorium: Harvey Brooks,” Woods Hole Oceanographic Institute, 3 June 2004, https://www.whoi.edu/main/obituaries/archive?tid=3622&cid=721 (accessed 1 August 2015).

37. H. M. Ellis, “The Application of Decision Analysis to the Problem of Choosing an Air Pollution Control Program for New York City” (Ph.D. diss., Harvard University, 1970); Ralph L. Keeney, “Decision Analysis of Environmental Problems” (Cambridge, Mass., October 1973), http://dspace.mit.edu/bitstream/handle/1721.1/47285/decisionanalysis00keen.pdf?sequence=1 (accessed 1 August 2015); Nuclear Energy Policy Research Group, Nuclear Energy Policy and Choices (Cambridge, Mass., 1977); Raiffa, Memoir, 141–42; Schwing, Richard C., and Albers, Walter A., Societal Risk Assessment: How Safe Is Safe Enough? (New York, 1980)Google Scholar.

38. Oreskes, Naomi and Conway, Erik M., Merchants of Doubt: How a Handful of Scientists Obscured the Truth on Issues from Tobacco Smoke to Global Warming (New York, 2010), 174–76 (on Schelling)Google Scholar; Raiffa, Memoir, 143–44; CORADM, Perspectives on Risk and Decision Making. The lone dissenter on the committee was the political scientist Charles Lindblom, who, having spent time at RAND in the mid-1950s, emerged as a strong critic of quantitative systems analysis. Jardini, “Out of the Blue Yonder,” 108–9; Charles Edward Lindblom, The Intelligence of Democracy: Decision Making through Mutual Adjustment (New York, 1965). John Graham, the committee staffer, would later found the Harvard Center for Risk Analysis and would head the Office of Management and Budget under Ronald Reagan. See Vogel, Is It Safe?¸ 160–61.

39. CORADM, Perspectives on Risk and Decision Making; Raiffa, Memoir, 143–44; Raiffa, “Decision Analysis: A Personal Account.”

40. H. Spencer Banzhaf argues that the decision to quantify life was forced upon RAND analysts by the political context of their work. While some certainly resisted this move in the early years, by the 1970s policy analysts readily embraced the question and typically pushed policy in that direction, even while recognizing its political unpalatability. Raiffa, for one, recalled teaching an entire class in which he asked the students to grapple with the topic, and CODRAM’s draft report had offered several options for doing just that. Banzhaf, “The Cold-War Origins of the Value of Statistical Life (VSL),” SSRN Scholarly Paper (Rochester, N.Y.: Social Science Research Network, 26 November 2013), http://papers.ssrn.com/abstract=2360205 (accessed 8 January 2015); Raiffa, Memoir, 143; Howard Raiffa, “Science and Policy: Their Separation and Integration in Risk Analysis,” American Statistician 36 (1982): 225–31; John D. Graham and James W. Vaupel, “The Value of a Life: What Difference Does It Make?,” in Risk/Benefit Analysis in Water Resources Planning and Management, ed. Yacov Haimes (New York, 1981), 233–43.

41. Alter, “Harvard versus Democracy,” 33; Graham, John D., “Historical Perspective on Risk Assessment in the Federal Government,” Toxicology 102, no. 1–2 (1 September 1995): 2952;Google Scholar Richard J. Ronk, “Oral History” (U.S. Food and Drug Administration, 10 May 1995), NLM, http://www.fda.gov/downloads/AboutFDA/WhatWeDo/History/OralHistories/SelectedOralHistoryTranscripts/UCM266256.pdf (accessed 25 March 2012); Nelson, “Office of Policy Analysis”; Levien, “RAND, IIASA, and the Conduct of Systems Analysis”; Raiffa, Memoir, 90–94.

42. For industry’s own uncertainty about risk assessment, see P. N. Lee, “Risk,” 12 December 1978, Legacy Tobacco documents, #zmbh0045, http://industrydocuments.library.ucsf.edu/tobacco/docs/ (accessed 30 July 2015); “Remarks of Dr. Weis,” CMA Executive Committee minutes, 27 October 1980, Chemical Industry Archives, http://www.chemicalindustryarchives.org. On reputation, see CMA Public Relations Committee minutes, 1 June 1977 and 15 September 1977, Chemical Industry Archives, http://www.chemicalindustryarchives.org/ (accessed 1 August 2105).

43. Vogel, Is It Safe?, 69–72.

44. MCA Executive Committee minutes, 5 September 1979, Chemical Industry Archives; “OSHA/AIHC Clash on Carcinogen Proposal,” BioScience 28 (May 1978): 311.

45. Raiffa, “Science and Policy,” 229.

46. Whitehead, “Uses and Limitations.” On the role of cost-benefit analysis in systems analysis at RAND, see Jardini, “Out of the Blue Yonder,” 121–25.

47. Richard Wilson was also a founding member of the Society for Risk Analysis and a faculty affiliate of the Kennedy School. “Richard Wilson,” http://users.physics.harvard.edu/∼wilson/cv.html (accessed 29 July 2015); “Summary of the OSHA Generic Carcinogen Hearing Proceedings, Seventh Week–June 26–30, 1978,” # lkfm0049, Legacy Tobacco Documents; U.S. Congress, House, Comparative Risk Assessment: Hearings Before the Subcommittee on Science, Research and Technology (Washington, D.C., 1980). On corporate funding of academic risk centers, see “They Bet Your Life,” Washington Post, 18 November 1979; “Remarks of Dr. Weis.” Nomination of John D. Graham,” 19 July 2001, Cong. Record, 107th Cong., 1st sess., v 147:13911ff. On corporate funding of early university-based toxicology, see Sellers, Hazards of the Job, 172–83.

48. American Industrial Health Council, “1980 Report to the Membership,” document #xtgf0097, Tobacco Industry Documents. Also in 1980, the U.S. Supreme Court in Industrial Union Department v. Occupational Safety and Health Administration, 448 U.S. 607 (1980), overturned OSHA’s proposed standard for benzene, arguing that the agency had not demonstrated a “significant risk.” Its decision cited the arguments of Richard Wilson. See “Sinister Side of Benzene Key to Case,” Washington Post, 3 July 1980.

49. U.S. Congress, House, Comparative Risk Assessment: Hearings Before the Subcommittee on Science, Research and Technology (Washington, D.C., 1980), 14–15 May 1980, 96th Cong., 2nd sess. For NAS’s ties to industry, see Philip M. Boffey, The Brain Bank of America: An Inquiry into the Politics of Science (New York, 1975), 53–88; Vogel, Is It Safe?, 55–56.

50. Reull A. Stallones and Thomas Downs, “A Critical Review of ‘Estimates of the Fraction of Cancer in the United States Related to Occupational Factors,’” # lyvb0104, Legacy Tobacco Documents.

51. Barry L. Johnson and James J. Reisa, “Essays in Commemoration of the 20th Anniversary of the National Research Council’s Risk Assessment in the Federal Government: Managing the Process,” Human & Ecological Risk Assessment 9 (2003): 1093; National Research Council, Committee on the Institutional Means for Assessment of Risks to Public Health, Risk Assessment in the Federal Government: Managing the Process (Washington, D.C., 1983), 7.

52. “Media Coverage Resulting from AIHC Tours,” [July?] 1983, #jfmy0104, Legacy Tobacco Documents; Soraya Boudia, “Managing Science and Political Uncertainty” (on AIHC publicity); Warner North, “Reflections on the Red/Mis-Read Book, 20 Years After,” Human and Ecological Risk Assessment 9, no. 5 (August 2003): 1145–54.

53. In fact, the Consumer Product Safety Commission’s recent risk assessment for formaldehyde, a chemical used extensively by Weyerhaeuser in the manufacture of wood products, was one of the case study documents considered by the committee. William M. Stigliani, “Case Study: CPSC’s Risk Assessment for Formaldehyde,” in National Research Council, Risk Assessment, Appendix C: Working Papers. www.nap.edu/read/776 (accessed 6 August 2015). Collins, Craig, Toxic Loopholes: Failures and Future Prospects for Environmental Law (Cambridge, 2010), 1011Google Scholar: Joel Klein, “The Plastic Coffin of Charlie Arthur,” Rolling Stone, 15 January 1976.

54. Ruckelshaus, W. D., “Science, Risk, and Public Policy,” Science 221 (9 September 1983): 1026–28Google Scholar; North, “Reflections,” 1151.

55. U.S. Environmental Protection Agency, Unfinished Business: A Comparative Assessment of Environmental Problems (Washington, D.C., 1987); Russell, Milton and Gruber, Michael, “Risk Assessment in Environmental Policy-Making,” Science 236 (17 April 1987): 286–90Google Scholar; Rechard, Rob P., “Historical Relationship Between Performance Assessment for Radioactive Waste Disposal and Other Types of Risk Assessment,” RISA Risk Analysis 19, no. 5 (1999): 763807;CrossRefGoogle Scholar Andrews, “Risk-Based Decision Making: Policy, Science, and Politics”; Richard N. L. Andrews, Managing the Environment, Managing Ourselves: A History of American Environmental Policy (New Haven, 1999), 266–70.

56. This, in fact, was the rationalization for Congress’s eventual overturning of the Delaney Clause in 1996 and its replacement by a single risk-based standard. Wargo, John, Our Children’s Toxic Legacy: How Science and Law Fail to Protect Us from Pesticides (New Haven, 1996), 284–86Google Scholar; Vogel, Is It Safe?, 122.

57. Theodore M. Porter, Trust in Numbers: The Pursuit of Objectivity in Science and Public Life (Princeton, 1995). On shifting power within agencies, see Hutt, “Brief History of Risk Assessment,” 15–16 (on resistance among FDA’s scientific staff); Nelson, “Office of Policy Analysis.” For a personal perspective on how risk assessment disempowered the authority of agency staff, see J. Clarence Davies, “The Toxic Substances Control Act: From the Perspective of J. Clarence Davies,” interview transcript, n.d., Chemical Heritage Foundation. For critiques, see Mirer, “Distortions”; Vogel, Is It Safe?, 159–64.

58. Raiffa, Howard, “Guest Editorial,” Risk Decision and Policy 1, no. 1 (1996): 13.CrossRefGoogle Scholar

59. Industry representatives had long argued that government should not have the authority to assess the benefits of chemicals, and had opposed FDA attempts to gain that authority in the 1950s. An NAS report on the evaluation of chemicals endorsed this position in 1975. Vogel, Is It Safe?, 37, 64. In response to the OSHA regulations, the AIHC funded a study that concluded OSHA’s proposals would raise the country’s already high inflation rate, “OSHA Workplace-Carcinogen Proposal Could Cost Billions of Dollars, Increase U.S. Inflation Rate,” AIHC Press Release, 28 March 1978, #fphm0146, Legacy Tobacco documents.