Public Policy Work
Kristin Shrader-Frechette

Much of Dr. Shrader-Frechette's public-policy work falls into two main areas: public-health ethics and environmental ethics, including environmental-justice issues, or methodological assessment of methods used in risk analysis. Some examples of her policy work are listed below.

Currently (2005-2006) Shrader-Frechette serves on the US Environmental Protection Agency Science Advisory Board where she works on problems of ethics and human eperimentation, ethics and risk, groundwater-contaminant modelling, assessing pesticide doses, evaluating the scientific and environmental aspects of the US President’s annual budget, and so on. Shrader-Frechette was named Chair of the EPA committee to evaluate the CHEERS study of pesticide effects on children. In 2004, she helped draft and write the US National Academy of Sciences directive on economic costing of ecosystems services, published as the book, Valuing Ecosystems Services, in 2004. She also worked with NASA to develop radiation-protection standards for astronauts, and in 2000-2002 served as the US member of the 6-person international committee of the International Commission on Radiological Protection, to develop United Nations radiation-protection standards for the environment. Parts of that report were issued in 2005 as ICRP radiation-protection norms.

In 2003-2004, Shrader-Frechette worked with the Canadian government in helping it to decide how to handle it high-level radioactive waste. Shrader-Frechette wrote one of the major position papers that was used by the Canadian government to make this decision .

Working with the Centers for Disease Control in 2001-2002, Shrader-Frechette also helped the ATSDR evaluate human health risks and ethical issues associated with fallout from US nuclear weapons testing. In 2001, Dr. Shrader-Frechette and her students helped the African-American community of Scarboro, Tennessee assess the community's exposure to high doses of beryllium, mercury, lead, PCBs, and ionizing radiation from a local facility. These exposures are believed responsible for a doubling of respiratory and pulmonary ailments among Scarboro children.

In 1999, Shrader-Frechette and her students evaluated the recently-completed, state-of-the-art analysis of the Chemical Manufacturers of America risk assessment on hormetic effects of low doses of hazardous chemicals. The analysis of scientific methodologies, a project in applied philosophy of science, showed that the scientific studies alleging hormesis violated a number of norms concerning biological endpoints, study duration, interpretation of results. The conclusion was that the hormesis claim was not epistemologically justified, and therefore, there ought not be a greater deregulation of low-dose organic chemicals. These results were published in 2001.

Also in 1999, Shrader-Frechette and her students worked on a critical ethical and scientific analysis of the draft environmental impact statement (EIS) for expanded operations of the Los Alamos National Laboratory Operations. Their research was sent to the NRC for input into the policy process. The thesis of the work is that the draft Los Alamos EIS failed to take adequate account of ethical problems raised by environmental-justice issues. In fact, the paper showed that the plan would violate the rights of the local Latino community to environmental justice.

In 1998, scientists at the Swedish Risk Academy and the Swedish Radiation Protection Institute asked Shrader-Frechette to provide an analysis of ethical issues in quantitative risk assessment, an analysis that they could use as a basis for Swedish regulations for ionizing radiation and for international recommendations on radiation standards to be proposed by the International Commission on Radiological Protection (ICRP).

Also in 1998, the Dutch government asked Shrader-Frechette and her students to critically evaluate the Dutch plan for storage and disposal of high-level radioactive waste in the Netherlands. Shrader-Frechette evaluated the Dutch plan, pointed out its ethical shortcomings, and wrote a position paper for the Dutch, after meeting in the Hague with Dutch officials in 1999.

Industries and developers typically place the most dangerous and undesirable facilities in poor, black, Latino, Native American, or Appalachian communities, mainly because suich communities often have neither the financial nor the political resources to insure that health and safety regulations are met and to insure that the siting process is a fair one. With her students, Dr. Shrader-Frechette performed a critical analysis and an ethical analysis of the presuppositions and methods in the quantitative risk assessment (QRA) and environmental impact assessment (EIA) being used by a multinational corporation (CEC) to site a hazardous facility in a poor, black community in Louisiana. Shrader-Frechette and her students were able to expose the faulty science and the faulty ethical analyses in the QRA and EIA. As a result, the black community was not subjected to this unwanted, disproportionate pollution from which they would gain no benefit. This philosophical and practical victory has become known as the first major environmental-justice victory in the US. Shrader-Frechette's publications (see her curriculum vitae for list) with student Dan Wigley - in 1994, 1995, and 1996 -- document these analyses that they performed, at the request of the black community in Louisiana.

In 1995, the US Presidential Commission on Human Radiation Experiments asked Shrader-Frechette and her students for opinions on the work of the committee and its recommendations. The committee used Shrader-Frechette's 1993 book, The Ethics of Scientific Research.

In 1995, the Governor's Conference of the United States voted to have Shrader-Frechette represent all the 50 states on the 6-person Blue-Ribbon Department of Energy (DOE) panel evaluating the scientific and ethical aspects of the the QRAs (quantitative risk assessments) done for the DOE sites for medium-level, chemically contaminated radioactive waste. Shrader-Frechette's 1995 and 1996 critical analyses of the DOE plans resulted in strengthened ethical and environmental plans for US waste disposal.

In 1994, US Senators and Congressmen asked Shrader-Frechette to critically evaluate House and Senate bills for scientific and ethical reform of quantitative risk assessment as part of the 104 th and 105 th Congress. Shrader-Frechette helped to strengthen this legislation and to defeat poor legislation, largely by working with New York Democratic Senator Moynihan.

Beginning in 1993, Norwegian officials asked Shrader-Frechette and her students to evaluate the ethical and scientific presuppositions of their QRAs (quantitative risk assessments) for North Sea oil drilling and for factory farming of salmon. Shrader-Frechette did these analyses and also offered courses, through the Norwegian Research Council, for Norwegian scientists on the ethical aspects of environmental and human-health risk problems. This work on Norwegian policy and with the Norwegian scientific community was published in 1996 as a volume from the Norwegian National Research Council.

In 1993, the International Atomic Energy Agency, a group under the United Nations, responsible for international radiation protection, asked Shrader-Frechette to perform an ethical analysis of the ethical issues underlying protection from radiation risk. This analysis was published in 1994 by the IAEA. Later, in 1999, the IAEA asked Shrader-Frechette to perform an ethical analysis of the draft document of the ICRP, Protection of the Public in Situations of Prolonged Radiation Exposure. Shrader-Frechette and her students provided this analysis in 1999 and, as a result, helped to insure greater ethical protection through radiation regulation.

Beginning in 1993, Shrader-Frechette served on the US National Research Council-National Academy of Sciences Board on Environmental Studies and Toxicology (BEST). Although she served in a variety of policy-relevant capacities, three of the most important committees on which she did scientific and policy work, as a committee member and in helping to draft the academy documents, were the Committee to Evaluate the US Army's Risk Assessment (of its biological-warfare experiments (zinc-cadmium sulfide dispersions)on US citizens); its Committee on Understanding Risk in a Democracy (which revised the norms for use of quantitative risk assessment) and its Committee to Evaluate the EPA EMAP Program.

In 1991, the Nevada Nuclear Waste Project Office (NNWPO), funded by the US DOE, asked Shrader-Frechette to do an ethical and epistemological analysis of the risk-assessment methods used in site studies for the proposed Yucca Mountain High-Level Nuclear Waste Repository. This analysis was published in 1992 by the NNWPO, and in 1993, Shrader-Frechette wrote the response (to the DOE) document for the State of Nevada for the Early Site Suitability Evaluation. This critical response of Shrader-Frechette helped point out methodological and ethical flaws in the DOE plan, and it helped turn the nation's experts away from permanent geological disposal and toward monitored retrieval storage of the waste, a more ethical and scientifically sound solution. Shrader-Frechette's analyses of permanent-geological, versus monitored-retrievable, storage were published in 1993 in her book from University of California Press.

In 1990, The World Health Organization and the United Nations asked Shrader-Frechette to write an ethical critique of early drafts of the UN's World Charter for Nature. The critique was necessary because, without it, the charter was demanding protection for all plant and animal species everywhere, under all circumstances, and was disallowing spraying to prevent malaria in developing nations. Thus the Charter, as written, would have indirectly caused the malaria deaths of thousands of the poor of the world. The critique developed a lexicographic scheme of strong rights and weak rights and argued for conditions that were necessary and sufficient to justify spraying on particular occasions. This ethical analysis was published in the 1991 World Health Forum.

In 1988 the World Council of Churches (WCC), headquartered in Geneva, Switzerland, asked Shrader-Frechette to travel to Kinshasa, Zaire to advise African leaders on the dangers of nuclear-power generation, radiation safety, and the ethical aspects of African nations' accepting radioactive and hazardous waste, in exchange for payment, from developed nations. Shrader-Frechette helped to lessen this international traffic in hazardous waste, and she edited a volume (1991), Nuclear Energy and Ethics, published by the WCC on this topic.

Beginning in 1980, Shrader-Frechette wrote a number of ethical and epistemological analyses (about 40 articles and 3 books) that were critical of the scientific methods used to justify shallow land disposal of low-level radioactive wastes. In part as a result of these analyses, the US Nuclear Regulatory Commission (NRC) changed its policies and disallowed shallow land burial by 1994.

In 1977 Shrader-Frechette was asked to serve on the US EPA's Ohio River Basin Energy Study, so as to evaluate the logical, methodological, and ethical aspects of the QRAs done for proposed nuclear- and coal-fired electricity generating plants. In part as a result of her analysis, two proposed nuclear generating facilities were not completed.

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August, 2002