Abstract

The risk regulation process has been traditionally conceived as having two components: a consultation of the experts concerning the magnitude of risk and a negotiated decision on whether and how to reduce that risk . The first component is generally thought to be free of the contentious value judgments that often characterize the second component. In examining the recent controversy over dioxin regulation, I argue that the first component is not value-free. I review three areas of science important to dioxin regulation: epidemiological studies, laboratory animal studies, and biochemical studies. I show how problems of interpretation arise for each area of science that prevent a clear-cut answer to the question: what dose of dioxins is safe for humans? Because of significant uncertainties in how to interpret these studies, there is significant risk that one will err in the interpretation. In order to judge what risk of error to accept, one needs to consider and weigh the consequences of one's judgments, whether epistemic or non-epistemic. Weighing non-epistemic consequences requires the use of non-epistemic values. Thus, non-epistemic values, or the kind that are important in risk management, have an important and legitimate role to play in the judgments required to perform and interpret the dioxin studies. The risk assessment component of the risk regulation process cannot be claimed to be value-free and the process must be altered to accommodate a value-laden science