Incineration risk perceptions and public concern: Experience in the U.K. improving risk communication

Waste Management & Research (1992) 10, 169-182

INCINERATION RISK PERCEPTIONS AND PUBLIC CONCERN : EXPERIENCE IN THE U .K. IMPROVING RISK COMMUNICATION Judith Petts Centre for Extension Studies, Loughborough University of Technology, Loughborough, Leicestershire, LEI] 3TU, U .K.

(Received 18 March 1991 and accepted 15 July 1991) Siting decisions for hazardous waste incineration continue to be delayed and impeded by adverse public reaction . Improved public relations and education of the public about risks are the favoured approaches amongst many experts and the industry for allaying public concerns . This paper identifies the limited potential for such strategies and advocates instead attention to the whole risk management system for hazardous waste siting decisions. The paper's conclusions and recommendations arise from an examination of the nature, sources and impact of public concerns about incineration in the U .K . Key Words-Incineration, hazardous waste, risk management, risk assessment, risk communication, public perceptions 1 . Introduction This paper examines the widespread NIMBY (not in my back yard) reactions to hazardous waste incinerators, particularly in the U .K . Strategies which are often adopted by the industry and by decision-makers to cope with such reactions range from trying to keep a low profile, to telling the public that they are being irrational, to providing technical reassurance in relation to design and operational control, to use of quantified risk assessment to show that the risks from such plant are acceptably low . Such strategies are failing if the objective is seen as improving public acceptance of such plant . Furthermore, such strategies have been failing for over a decade . In the U .K ., as in a number of other European countries and North America, the siting decision process for new plant is being substantially lengthened as local communities object to proposals and force more open discussion of the risks and benefits . In some cases approval will eventually be given, but at the expense of delays, costly proceedings and, most importantly, continued lack of confidence amongst communities in the risk decision and control process . At worse there is a danger that in some countries insufficient incineration capacity may be available in the right location to provide for the Best Practicable Environmental Option to handle certain wastes . Industry and decisionmakers need to take urgent action to improve the public image . Risk communication needs to be improved within the context of the risk management system for incineration . 2 . The risk management system Risk management is the general term normally applied to the whole process of risk identification, estimation, evaluation, reduction and control (Fig . 1) . It can apply to any 0734-242X192/020169 + 14 $03 .00/0

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Risk reduction Risk assessment Risk analysis

Risk evaluation

Activity characterization

Option analysis

Hazard identification y Risk estimation

Implementation 1, Monitoring

Decision making

Audit/review

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Fig . 1 . Risk management system .

decision process where risk is an issue . It can be considered to have seven phases each incorporating a potential number of actions according to the decision required, e .g . siting a new plant, auditing the health and environmental impact of an existing plant, setting emissions standards, etc . (Petts in press) : (1) Activity characterization : identification of the structure of the activity and process operations . (2) Hazard identification : substance and hazard identification ; fault and event tree analysis; toxicological studies ; epidemiological investigations . (3) Risk estimation : quantitative analysis of toxicological or epidemiological data ; transport and fate modelling ; estimation of levels of human exposure ; doseresponse extrapolations ; exposure rate-duration and magnitude ; assessment of probabilities of damage . (4) Option analysis : consideration of mitigation and design options ; regulatory control, non-regulatory controls ; cost identification . (5) Decision-making: judgement of the significance of the assessed risks ; risk-benefit analysis; risk acceptability evaluation ; economic impact analysis ; consideration of uncertainty in risk estimation . (6) Implementation : development of implementation strategy ; examination of policy options ; siting decisions ; plant design and layout ; implementation of quality systems; emergency planning . (7) Monitoring : environmental monitoring ; operations auditing; prospective epidemiology ; new health risk information . (8) Audit/review : (which can lead back to re-examination of any of the above phases) . Phases 1-5 inclusive are often referred to as "risk assessment", phases 5-8 inclusive represent "risk reduction" . Risk assessment and risk reduction therefore overlap . The purpose of risk management can be identified in the following aims : (1) To control and reduce risks to acceptable levels . (2) To reduce uncertainty in risk decision-making . (3) To increase public confidence in decisions about risk . Given these aims it can readily be seen that probably the single most important element of risk management is the transfer of risk information (or risk communication),



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between those measuring the risk and those who have to make decisions (formal and informal) about the risk . 3 . Risk communication and risk management Risk communication can occur at all of the stages of the risk management process . Indeed, communication of risk information is a critical component of the whole process . Risk communication has been formally defined as "any purposeful exchange of information about health or environmental risks between interested parties" (Covello et al. 1986) . The interested parties in the risk management process could include any, or all, of the following : government/regulatory agencies ; local authorities ; corporations and industry ; trades unions ; the media; scientists and independent experts ; environmental consultants ; professional organizations and institutions ; public/environmental interest groups ; local community/action groups; individual citizens . From the viewpoint of the "expert" or industry or regulator who is trying to communicate there may be a number of different objectives: (1) Reassurance : e .g . as to the ability of regulatory control to detect hazardous conditions ; the ability of operators to prevent accidents ; the ability to mitigate adverse impacts ; the degree of expert understanding and agreement . (2) Persuasion: e .g . as to the appropriateness of standards ; the appropriateness of the site choice; the appropriateness of the risk-cost/benefit trade-offs . (3) Arousal : e .g. hazard awareness ; appropriate emergency action to take; required behavioural change . (4) Education: e .g . as to the characteristics of the industry ; the competence of the operator and regulator . However, the communication process will be affected by a number of problems (Covello 1989) : (1) Message problems : e .g. deficiencies in knowledge and scientific understanding ; large uncertainties in risk estimation ; highly technical language . (2) Source problems : e .g . disagreements between experts ; resource limitations which prevent reduction of uncertainty ; use of technical or legalistic language leading to a lack of trust and credibility in experts ; limited understanding of the interests, concerns, and preferences of different communities . (3) Channel problems : e .g . biased media reporting ; premature disclosure of information ; inaccuracies in interpretation of information, one-way information flows ; over-simplifications, distortions, inaccuracies in technical information . (4) Receiver problems : e .g . lack of interest ; inaccurate perceptions ; unrealistic expectations about the effectiveness of regulatory action ; reluctance to make trade-offs between risks and costs ; difficulties in dealing with probabilistic information ; suspicions of industry's motives . Experts and industry are often heard to announce that better communication is the way to make the public agree with a position . However, the reality is more complex than this . Often the public may understand perfectly well what is being said, but they still disagree with the "expert" because they are starting from a different value judgement position . Poor communication may be evident, but risk acceptance disputes often reflect more fundamental differences in the way risk allocators deal with scientific and societal uncertainty, and the way that the different communities at risk view these questions .



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Risks, costs and benefits are often distributed unevenly through a society (local, regional and national) . In order to be acceptable the risk management process must be able to consider issues of equity, or fairness, in the distribution of these, e .g . consideration of the ability of different people to bear risks, whether compensation should be paid to those who have to bear disproportionate risks, and whether the consent has been obtained from those who must bear the risk (Kasperson & Kasperson 1984) . The risk management system must allow for the full participation of the risk bearers in the decision process . This requires that communication and information flows are in a two-way direction, that information is openly available at the right time in the decision process, and that the decision-making mechanisms and forums themselves allow for participation and exchange of views . 4. NIMBY reactions and public perceptions "There is probably no single hazardous waste issue that has received more attention than the siting of hazardous waste facilities . Not even the actual or potential threats to human health and the environment from the mismanagement of hazardous waste quite captures the attention and stimulates emotions as much as the public's opposition to siting new hazardous waste facilities ." (Hirschhorn 1984) It is instructive that this quote is from a 1984 paper by a member of the U .S . Congress Office of Technology Assessment . The paper concluded that the attention to the siting problem was actually misplaced and that attention should focus on building confidence in government and private programmes and institutions rather than attempting to change public perceptions about the risks . Whilst the paper was focusing on landfill disposal its message is one that is appropriate to treatment facilities as well . Indeed, a previous paper in the same journal (Portney 1984) concluded that the only way to allay the NIMBY syndrome in relation to treatment plants was to build confidence in the design, safety, and control of such activities, even preferring this strategy to attempts to compensate people for bearing risks . In general people find it difficult to put a monetary value on involuntary risk benefit . Our understanding of why people might believe hazardous waste facilities to be unacceptably risky has been assisted by the psychometric studies of risk perception which now have a 20-year history at least . Such studies (e .g . Slovic et al. 1980) point to characteristics such as involuntary risk, risks providing no direct personal benefit, potentially catastrophic risks, risks from new technology, risks to the health of future generations, as all providing for public concern . However, the limitations of such psychometric studies in helping us to understand how to deal with public concern have also been recognized . Sandmann (1988) has attempted to explain people's fears and concerns about industrial hazards as a product of outrage rather than of hazard, and identified the public's lack of trust in responsible authorities and industries as one of the important sources of outrage . The risk communication literature has explored this issue of trust and credibility further (e .g . Cvetkovich & Wiedemann 1988) and identified the need to tailor risk communication and management strategies to specific problem issues and to allow in the decision-making process for debate and argument not only about technical assessments of risk and prevention control procedures, but also about costs and benefits of industrial activities and ethical and moral questions about imposed hazards, threats to the environment and future generations, etc . The public prefer strategies of risk detection and mitigation to strategies of risk prediction and prevention, and strategies that strengthen social control mechanisms to those that strengthen technological control mechanisms (Elliot 1984) . Whilst experts tend to talk in terms of



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harm, probability, mortality, etc . the lay community tend to see risk as being attached to catastrophy and moral issues of fairness and credibility (O'Riordan 1990) . 4 .1 Incineration and NIMBY in the U .K. The House of Lords Select Committee on Hazardous Waste Disposal, in 1981, concluded that public hostility to hazardous waste disposal facilities is common and too important to be ignored . Ten years later in Britain we seem to have made little advance in terms of combating public hostilities, so much so that of at least 17 high temperature incinerator planning (siting) proposals for chemical and/or private sector clinical incinerators since the beginning of 1988 half have been refused at the first stage (Table 1), often resulting in costly appeals and public inquiries and failing to improve public confidence in, and acceptance of, the industry . We await decisions from the Secretary of State for the Environment on a number of these applications . Those applications that have been approved at the first stage have mainly been where existing incineration

TABLE 1 Some incinerator applications in the U .K ., 1988-1990 1 . Wellcome Foundation, Dartford, Kent 2 . Ocean Environmental Management, Seal Sands, Middlesbrough 3 . Leigh Environmental, Doncaster 4 . Leigh Environmental, Trafford Park, Manchester 5 . Fine Organics, Middlesbrough 6 . Northumbrian Water & ITC, Tyneside 7 . Northumbrian Water & ITC, Teesside 8 . Rechem, Fawley, Hampshire 9 . Cleanaway, Ellesmere Port, Cheshire 10 . Waste Management, Kirkby, Merseyside 11 . Northumbrian Water, Gateshead, Tyneside 12 . John Riley, Motherwell, Glasgow 13 . Leigh Environmental, Four Ashes, Wolverhampton 14 . Greater Manchester Waste Disposal Authority, Altrincham, Cheshire 16 . Caird, Middlesbrough

17 .

Grundon, Colnbrook, West London

Liquid waste In-house 30,000 tpa Rotary kiln

Granted

25,000 tpa Rotary kiln 26,000 tpa & 15,000 tpa Rotary kiln & clinical Additional capacity In-house Chemical waste and sewage sludge Chemical waste and sewage sludge Rotary kiln addition Rotary kiln replacement

Permission refused Public Inquiry 1990 Planning permission refused Granted

Permission refused Public Inquiry 1990-1991

Permission refused Public Inquiry 1990-1991 Permission refused Public Inquiry 1990-1991 Opened 1990 Opened 1990

Clinical Clinical Clinical Clinical

Refused 1990 Appeal lodged Refused 1990 Appeal lodged Permission granted 1990

Clinical

Permission granted at detailed application stage

Clinical

Planning permission refused 1990 Public Inquiry Opened 1990

Clinical

N .B . Hospital clinical incineration proposals excluded .



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capacity existed on a site, or where applications are for in-house plant on chemical sites . A number of applications for sewage sludge incinerators, by Yorkshire Water, have been successful, but mainly because they have not tried to develop capacity for chemical wastes as well (unlike Northumbrian Water) . We expect further applications by other water companies for sewage sludge incinerators following the required termination of sea disposal, by 1998, and the need to handle additional quantities which will be generated by clean-up programmes for coastal sewage discharges following the European Community Waste Water Treatment Directive . It will be interesting to see whether NIMBY reactions slow the progress of these developments . Local communities do not want chemical or clinical waste incinerators in their back yards . Paradoxically a local study of the public perception of landfill disposal indicates that if given a choice incineration is seen as a preferred waste management option (Lowe 1990) . The House of Commons Select Committee Report on Toxic Waste (1989) concluded that "high temperature incinerators are a safe and effective method of toxic waste disposal", yet this view is not supported by local communities faced with actual applications for new facilities . This compares with an apparent lack of public response to a House of Lords Select Committee on the European Communities Report (1989) which suggested that not a single municipal incinerator in Britain could meet new European Community emissions requirements . Generally, municipal incinerators and crematoria appear to meet with relatively little public concern, although until 1990 there had been very few new facilities which could test concern over siting of such facilities. The NIMBY reactions to proposals for new incinerators witnessed in Britain represent a complex response to a number of different yet interrelated concerns, and the very complexity of these reactions makes any attempts to improve risk communication within the risk management system that much more difficult . Examination of local community responses to five of the current incinerator applications (2, 3, 4, 6, 7 in Table 1), looking at issues raised by local action groups, local parish and district councillors, and individual members of the public, indicates four main concerns : (1) (2) (3) (4)

The health effects of incinerator emissions . Potential accidents involving "toxic" waste . Adverse impact on the quality of life . The management of industrial waste .

Subsumed within these four areas are a multitude of other concerns (Table 2) ranging from the type of risk perceptions common to many industrial activities-e .g . an unknown, involuntary risk, of no direct benefit to the local community, lack of trust in operators and regulatory authorities-through to specific concerns about the handling of hazardous wastes and the safety of operation of incinerators . Common subjects which raise particular emotions are "dioxins", "toxic waste", "PCBs", "waste imports", and the general nature of "waste", i .e. material is more dangerous when it is waste than when it is a raw material . At this point it is appropriate to note that chemical waste incineration in the U .K . (four operating merchant sector sites) is entirely in the hands of the private sector . Further, there has been relatively little attention to energy recovery schemes in relation to incineration, i .e . schemes that might provide for some visible benefits for local communities, and there are two current proposals for energy from waste plants . The general NIMBY reactions appear to have their source in a few key areas (although it is recognized that in specific locations a number of local issues and concerns will also influence reactions, e .g . experience of a specific plant or accident, proximity of plant, socio-economic characteristics of residents) :



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TABLE 2 Public concern about incineration Concerns

Nature of concern

Emissions-long-term health effects potential genetic effects

Threat to children Unseen-unknown hazard Lack of expert agreement on hazards, emission models, etc . Apparent evidence of adverse health effects in those living near plants No opportunity for public control Specific fears of the unknown, e .g . dioxins

Accidents and exposure to chemicals on site and during transport

Lack of trust in operators to control operation and mitigate accidents Lack of trust in regulatory agencies to monitor operations and to identify problems Specific fears, e .g. transport accidents in nearby residential areas Waste more dangerous than product

Management of industrial wastes

No local benefit from operations Concern about being a dumping ground for imports Concern about generation of "toxic" wastes by industry Conflicting perceptions of how to manage toxic wastes Waste management industry seen as lacking in professionalism Waste materials less well handled than new products/materials

Adverse impact on quality of life

Concern over property values No compensation An imposed hazard Concern over loss of local amenity

(1) The extremely poor image of the waste industry generally, and doubt as to its professionalism . (2) Mistrust in the state of knowledge about the risks from incinerator emissions and in particular fears of long-term health effects . Two plants operated by Rechem (one now closed) have been a source of particular local public concern about health damage for over 15 years and have been the subject of national media coverage . (3) The failure of environmental, and risk, assessments to communicate adequately the nature and extent of the impacts . (4) A lack of any strategic planning for waste disposal facilities .

4 .2 The image of the U .K . waste industry The House of Commons Environment Committee Report of 1989 on Toxic Waste was one of the most forthright reports ever to come from the Select Committee . Whilst it



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talked favourably about high temperature incineration, waste disposal practices and waste regulation were criticised for variability in standards and low professionalism in some sectors . The publication of the report coincided with national press coverage of imports of waste into the U .K . with captions referring to the country as being the "dustbin of Europe" . The waste industry is still trying to raise its professional status in the public's eyes . Waste imports have declined by over 60% in 4 years (currently representing less than 0 .01 % of total "home" arisings of controlled industrial, commercial and household waste) as the Government has moved to discourage the import of waste for direct landfill and the implementation of the Transfrontier Shipment Directive has had some impact . However, the public view of the country as a "dustbin" and of the industry as only being interested in large profits rather than environmental protection does not seem to have changed if the evidence of the press is correct . Furthermore, the regulatory system is not seen as competent . The House of Commons Report referred to the variability in standards amongst different Waste Disposal Authorities (local licensing and enforcement authorities), and over the last 2 years Her Majesty's Inspectorate of Pollution (HMIP) (which has a central auditing and advisory function) has been visibly short-staffed and affected by resignations of some key staff . It is HMIP that will take over (from Waste Disposal Authorities) the licensing control of chemical waste incinerators under Part 1 of the 1990 Environmental Protection Act (which introduces integrated pollution control) . However, there has been vocal concern during some recent planning applications that HMIP will not be able to carry out its functions effectively . Finally, in the U .K . at least, there appears to be particular public concern about the private sector dominance of the handling of hazardous wastes . During the planning committee discussion of Ocean Environmental Management's application on Teesside, for example, there was some evidence that the local community would be happier if the plant was to be operated by the public sector, despite the fact that many municipal incinerators and hospital incinerators operated by the latter are known by the expert community (if not the public) to require major improvements in design, to meet current standards, and in operational control . 4 .3 The "Rechem issue" Rechem was founded in 1968 and had three high temperature incinerators : at Bonnybridge (north-west of Glasgow, Scotland), Pontypool (Gwent, South Wales), and Fawley (south of Southampton, Hampshire) . Bonnybridge and Pontypool have been licensed to incinerate PCBs . In 1977 a farmer reported high mortality in livestock on a farm near Bonnybridge . Independent investigations of the claims by the Department of Agriculture and Fisheries, Scotland, and Glasgow University Veterinary School could find no linkage to Rechem . This was followed by reports of two babies being born with rare congenital eye defects in the area . Welsh Office officials were instructed to examine similar data for the area around Pontypool but no significant increase in cancer registrations was found . Indeed the Industrial Air Inspectorate reported Pontypool to be operating satisfactorily . In November 1984 Rechem announced the closure of Bonnybridge for economic reasons . The results of a subsequent monitoring programme set up by the Harwell Laboratory (part of the U .K . Atomic Energy Authority) and Rechem, independently, showed no abnormal levels of soil PCBs, and the Lenihan Inquiry Report published in February 1985 cleared Rechem and dismissed links between morbidity at Bonnybridge and incinerator emissions .



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A Welsh Office Report published at the same time reported increased levels of anencephalus and polydactyly in Pontypool, but overall found no statistically significant increase in the eye defect considered by Lenihan . The local Borough Council (Torfaen) took Rechem to court on behalf of four local people for infringements of licensing conditions . The company installed £1 .8m worth of gas-cleaning equipment at the plant . At the same time they were acquitted of five criminal charges . Since 1986 there has been continued press reporting of evidence of increased cancer risks around the site, demonstrations by a vociferous action group, Mothers and Children Against Toxic Waste, national television coverage of imports of PCB containing waste, a delegation visit by the Borough Council to the European Commission legal department expressing concern over PCB contamination, a report by the University of Wales which found "high levels" of PCBs in some chicken and duck eggs in the area, and another call for a public inquiry into the plant . In December 1990 Rechem merged with Shanks and McEwan Ltd (SME) making SME the largest waste management company in Britain . SME's managing director has said that the company will be more open in dealings with the public . To this day the Pontypool plant provides an ongoing source of local public concern and mistrust, to the extent that it sometimes seems unlikely that such ingrained and highly developed emotions could ever be fully dissipated, despite efforts to form local liaison committees, the assurances from the managing director of SME, and most importantly no scientific evidence, to date, of any direct link between the plant and health effects . Early in 1991 the U .K . Government invited the European Commission to participate in a study of the environmental impact of the Pontypool incinerator . The Commission's involvement is without precedent . It is instructive to note that the Rechem plant at Fawley has not suffered the same degree of local animosity (it does not handle PCBs) nor has the Cleanaway incinerator at Ellesmere Port, which is licensed to burn PCBs . The latter plant is an industrial area with relatively little housing in close proximity compared with Pontypool . The Rechem issue, whilst primarily a local issue in that it relates to the operation of two plants, has undoubtedly provided ammunition for other local communities opposed to new facilities in their localities, and has provided for national media attention to hazardous waste incineration . In particular it has focused attention on the perceived health effects of emissions from incinerators and upon PCB handling, including imports (two of the four main concerns noted in Table 2) . 4 .4 Environmental assessment and risk assessment Lack of firm scientific evidence as to the health effects from incinerator emissions provides the lay community with continual ammunition against the industry . In Britain, with the implementation of European Community Directive 85/337/EEC by means of the Town and Country Planning (Assessment of Environmental Effects) Regulations (1988), all applications for hazardous waste incinerators must be accompanied by an Environmental Statement (ES) the outcome of an Environmental Assessment (EA) undertaken by the developer . This provides for the full assessment of the likely significant effects of plant, the impact on the public and the environment, and identification of appropriate plant design and operation to mitigate any adverse impacts . As a public document an ES should provide for effective risk communication and for discussion at the decision-making stage of the appropriateness of the site, design, and planned operational characteristics . To date the quality of ESs produced has been highly variable, the most common



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inadequacies including a failure to discuss the main alternative sites and processes considered, to identify accident scenarios, to address all significant aspects, and to consider risk as opposed to hazard . In almost all cases relating to chemical waste incinerators, the developer has commissioned independent consultants to undertake the assessment and produce the ES ; the local planning authorities have also used consultants (both formally and informally) to review the assessments . Even the better assessments have not been successful in allaying all of the local community's fears or fully addressing decision-making information requirements . Certainly an ES should assist the latter ; however, it is unrealistic to expect such a document to achieve the former, rather a competent ES should form an important component of an improved risk communication strategy . Risk assessment should be applied to proposals for new incineration capacity as part of the environmental assessment process if the potential impact on the environment is to be properly assessed . Consideration of "hazard" is implicit in the planning and licensing process, e .g . requiring bunded and paved areas to prevent the migration of spills . However, attempts to translate a hazard assessment into a risk estimate of the likelihood of an adverse event actually occurring and affecting a "target" in a particular time period, and the application of criteria of acceptability to this risk estimate, are comparatively recent-certainly compared with experience in relation to major hazard installations (i .e . in relation to acute accident hazards as compared to chronic effects of continuous releases), and compared to experience in the U .S . where risk assessment is established as a necessary tool for demonstrating the validity of siting and design criteria for waste disposal and treatment . Risk assessment is an uncertain process . Particular areas of uncertainty in the risk estimation process for incinerators are : in the characterization of waste streams ; in the models for dispersion and subsequent deposition of the constituents of the stack gas ; in attempts to quantify indirect exposure, e .g . through the food chain and dermal exposure ; the relationship between dose and response for carcinogens when assessing toxicity ; the quantification of non-carcinogenic effects (currently there is no widely accepted methodology) . Generally there is the potential to overestimate risk, e .g . through the use of linear multi-stage dose-response models to predict human cancer risk at low doses . Unfortunately some experts are so concerned about the sensitivity of quantified results to these uncertainties that they shy away from the process . However, "what is of paramount importance is that those who produce and those who use the risk numbers are aware of the inherent uncertainties, so that any judgements or decisions which result are taken in this knowledge" (Health & Safety Executive 1989) . In the U .K . we are only just beginning the process of quantifying risks for new plant . The final task of the risk assessor is to set some criteria for the acceptability of the estimated risk, i .e . at what point does the assessed risk of harm or damage become unacceptable . This criteria should be derived by a full understanding of public concerns, by comparison with apparent acceptability of other risky activities which are perceived in a similar way, by a full understanding of the costs and benefits of the activity . In the U .K . we have moved to discussion of "tolerable" as opposed to acceptable risks in recognition of the fact that involuntary risk is rarely acceptable, but may be tolerated by the public if they are confident that it can be controlled and there are some benefits to be derived (Health & Safety Executive 1988) . Acceptable risk criteria have been published in relation to major hazard risks and researchers are gathering experience of their use in the risk management system . The criteria relate to the risk to an individual and are related to specific development types in the vicinity of major hazard plant : 10 X 10 -6 risk



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of individual harm for small housing and community facilities, through to I x 10 -6 for larger developments, through to 3 x 10 -7 where particularly sensitive populations are involved . There is a need for development of societal risk criteria, particularly where accidents could cause many casualties . Futhermore, the use of such national criteria at the local level can be difficult and experience is that criteria should allow for local interpretation relative to the economic and social needs of a particular community at a particular time . The use of such criteria for major hazard siting decisions, where risk assessment has become an essential tool, is leading to pressure to develop similar tools in relation to other risky activities . Importantly the latter should come from a central agency whose expertise is recognized (as in the case of major hazards and the Health & Safety Executive) if they are to be accepted . 4 .5 Strategic siting issues

The U .K .'s free-market, non-interventionist policy approach to waste management is evident in the private sector dominance of the hazardous waste treatment market, and the devolution of facility siting and planning responsibilities to the local authorities . Whilst the local land-use planning system is effective in providing for, and controlling, local infrastructure and housing development, it is often less effective where facilities have a strategic importance (whether regional or national) . Problems have been compounded by the paucity of long-term planning for waste disposal facilities by the waste disposal authorities (a separate function from the land-use planning authorities), the lack of comprehensive and accurate data on waste arisings which can assist in identification of required disposal and treatment facilities, and the lack of any regional planning to provide for the optimum siting of required strategic facilities (such as chemical waste incinerators) . The result has been a total lack of discussion and assessment in the public domain of the need for incineration capacity and the optimum siting of such facilities on a national basis which can minimise inequities in risk bearing, and the consequent misuse of the planning inquiry system to deal with such questions after-the-event (i .e . after a specific proposal in relation to a specific site) . In relation to applications numbers 2, 6, and 7 in Table 1, the Secretary of State for the Environment required the novel use of a two-stage planning inquiry with the first stage devoted to the question of need . In effect he will make a strategic decision on siting when he decides the outcome of the inquiry . However, this process of ad-hoc decision-making on the question of need and strategic siting cannot provide for full participation by different local communities . The Government is looking to strengthen the link between the waste regulation functions and land-use planning functions at the local level and to encourage voluntary groupings of authorities on a regional basis . In relation to EA there is some pressure for its use in relation to policies as well as specific project proposals . 5 . Summary and the way forward In the U .K . the development of the risk management system for major hazard installations (particularly the use of quantified risk assessment in siting decisions) and of risk communication within that system (particularly the public discussion of risk acceptability criteria) provides for some relevant experience and ideas as to how to improve the risk management system for waste incineration . Experience of this major hazard risk management system suggests that :



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(1) Risk communication must be a two-way process ; a process of bargaining . Statutory authorities and industry must expect to learn and be prepared to change opinions and stategies, as must the public . (2) Risk communication which is perceived as simply risk education is unlikely to be effective, because it will almost certainly fail to address the main concerns of the public and information requirements of decision-makers . (3) Risk communication is an ongoing process ; it is not simply a specific assessment in response to questions on a specific planning application . Discussion of risk control stategies ; provision of information on site control and operations ; ongoing liaison between statutory authorities, industry, local communities and the media all form an important part of risk communication . (4) Quantified risk assessment is becoming an essential element of siting decisions where risk is a dominant factor or is perceived by the public to be a dominant factor . Subjective discussion of "small", "low", "insignificant" etc . risks is no longer acceptable . (5) Risk acceptability is location and time dependent . Risk communicators must understand the specific elements of the risk concerns for specific siting decisions (Petts 1990) . Improving the risk management system for incineration is going to require a multilayer approach, i .e . improving risk communication in each phase of the system, and not just waiting until the siting-decision stage and hoping that reassurance and persuasion will be effective . Industry and experts can do a lot to improve their actual form, method, and timing of direct communication . Covello suggests nine rules for informing people about risks (1989), including being honest and frank, meeting the needs of the media, speaking clearly and with compassion, listening to your audience, directing specific information at specific elements of your audience, etc . However, these rules perhaps concentrate on the themes of persuasion, involvement, and informing . In practice what is required is attention to these areas together with attention to the actual control and operation of plant . Specifically, attention needs to be focused on : (1) Building confidence in the professionalism of the waste industry, i .e . actually improving professionalism . This will require more education and training, as well as better enforcement of standards . The incineration sector is suffering to a certain extent from the reputation of the landfill sector . The implementation of the Environmental Protection Act, 1990, should have some impact, e .g. facilities can only be operated by "fit and proper persons", waste handlers will have a statutory duty of care to handle waste and dispose of it correctly . (2) Building trust in the competence of the risk assessors, i .e . providing for enhanced understanding of, and agreement upon, the risks . There is further need for health risks studies . In the U .K . the Small Area Health Statistics Unit is currently undertaking a study which includes incinerators . (3) Improving the risk assessment methodologies, including providing for expert agreement on the use of specific models . The lead in development of such models must be taken by a central agency with credible status, and involving independent experts . There is also a need to improve the Environmental Assessment process, including registration of competent consultants . (4) Reducing risk to the lowest technological possibility, for example, through continuing improvements in emission-control equipment and use . It will be



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necessary to consider the best technology in terms of the relative costs of its adoption and use . (5) Providing for appropriate and effective public decision-making arenas, particularly in relation to strategic siting of hazardous waste facilities . (6) Improving the monitoring and auditing of facilities, to ensure rapid detection and mitigation of problems . (7) Ensuring adequate resourcing of control and enforcement agencies . (8) Providing for public information on the results of the monitoring and auditing process to allow for public input to decision-making . Legislation is providing for public registers of licence information, including information on prosecutions and enforcement action which should provide for more direct public monitoring of operations. (9) Providing for health surveys in specific areas where there is concern about existing plant, and for improved provision of information, and counselling, about health impacts at the local level . Local medical practitioners may need guidance to help them deal with the effects of stress arising from concern about the safety of plant . (10) Providing for more and better training of local planning officers, responsible for siting decisions, in technical issues, and improving the consultation process and liaison between planners and other statutory agencies . (11) Improving the liaison and communication between operators of specific plants and their specific local communities, including for example setting up local liaison committees, holding open days, talking to local groups and schools, etc . Operators need to be more proactive in their dealings with local communities . (12) Education of the media to try to provide for more accurate reporting (even if balanced reporting is difficult to achieve) . (13) Improving understanding of the different social meanings of risk amongst different parties . Further risk perception work specifically in relation to waste disposal activities is appropriate . This should assist companies in relation to (11) above, but also help to understand public preferences (revealed and expressed) to help in identification of appropriate risk/cost benefit trade-offs . (14) Providing for equity in risk-bearing amongst different communities and appropriate compensation where this is not possible . This is perhaps the most difficult area. Incinerators provide little direct benefit to communities in terms of employment, although there will be indirect local market spin-offs . In the U .K . to date one potential benefit, energy recovery, has been under-explored . Therefore other forms of compensation might appear appropriate, e .g . compensation for loss of property value, provision of services to the community by the operator, payment of inflated business rates to reduce the burden on householders, etc . However, there is evidence from the U .S .A . that communities prefer risk reduction strategies to compensation payments . (15) Providing for public discussion of alternative risk management strategies, e .g . is incineration the Best Practicable Environmental Option for certain wastes? Minimization of waste arisings as the preferred European waste management strategy is beginning to be taken seriously by the large industries, not least as disposal prices rise . Waste should be treated as seriously and responsibly as raw materials and product . There is no direct simple answer to allaying the NIMBY syndrome in relation to incineration . Attention to improving the whole risk management strategy is required .



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The overall theme is the need to increase the involvement of communities in risk decision-making and to do this the need to improve the framework and methods of risk communication . All of the "actors" in the risk management system have a responsibility .

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