Managing hazards in place: The risks of residual risks
Managing hazards in place (MHP) is a policy instrument in environmental health that allows less than complete removal, abatement, or remediation of environmental hazards. The practice of minimizing exposure to hazards rather than removing them is widely recognized as part of the toolbox of environmental protection for human and ecosystem health. The concept of managing hazards in place is embedded in several environmental statutes and regulations in the US notably the waste management regulations, as well as in the Safe Drinking Water Act and the Clean Water Act. While this commentary focuses largely on applications of MHP in the US, this policy is also utilized by agencies in many other countries for managing hazardous waste sites, lead in housing and drinking water systems, and environmental contamination of rivers and estuaries.
The rationale for this concept is not difficult to understand: MHP policies can reduce the costs of meeting environmental goals; it can provide opportunities for access to resources that have been contaminated by past actions such as waste disposal, and it can enhance land and property values as well as tax revenues all of which are important to home owners and communities. The concerns related to this concept are also not difficult to understand: an incompletely abated or contained hazard may present future exposure risks to humans and environmental biota. Further, the compromise implicit in MHP is the assurance of indefinite oversight and monitoring to detect any releases. To that extent, MHP involves both sociology as well as toxicology and the exposure sciences. Because of the prevalence of managing hazards in place, this commentary suggests that evaluation of its performance is needed.