Current approaches to regulatory risk management based on standard-setting assume that the standard represents a permanent best practice and a level of risk that is appropriate for the level of protection required by the community at risk. However, new information, improved scientific methodology, and the identification of novel risks often require review and modification of standards for significant hazards. As well, social attitudes change and society generally becomes more risk-averse over time. An alternative approach is ‘continuous quality improvement’ (CQI), which is an on-going process for the optimisation of risk, efficiency of operations, and consumption of resources. The ‘Deming Cycle’ (Plan→ Do→ Study→ Act→ [repeat]), for example, is the standard management approach for quality assurance in the private sector. CQI has advantages over fixed standard setting in improving the quality of the environment and worker health and fits better with good management practices. The theoretical disadvantages may be business concern over an ever shifting target for compliance and the opportunity cost of making improvements when performance is already sufficient. However, in practice, CQI has shown such great benefit in improving the operations of enterprises from small business to large corporations that it is standard procedure and typically results in large unanticipated gains beyond quality, in efficient operations, lower cost, and reduced risk. This approach is rarely used in occupational health protection but it has been adopted as ‘Best Available Control Technology’ in other settings. In the United States, the mandated periodic review of ambient air quality standards by the EPA and of high-priority chemicals under the Lautenberg Chemical Safety Act are broadly compatible with CQI. The approach is also one means of effectively operationalizing the Precautionary Principle. It is suggested that CQI should be reconsidered as an alternative regulatory approach and adopted as a fundamental approach to risk management.
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