Risk Analysis, Vol. 20, No.

2, 2000

Perspectives

Risk Management across the Globe: Insights from a

Comparative Look at Sweden, Japan, and the United States
Ragnar E. Lfstedt,1* Saburo Ikeda,2 and Kimberly M. Thompson3

In light of the present day risk controversies such as global warming and hormones in beef,
partially caused by a more globalized world, national differences and similarities in how to
manage risks become increasingly important. In this brief perspective we focus on how
risks are managed in three nations, namely Japan, Sweden, and the United States, specifically
focusing on the roles of deliberation, risk analysis, and the importance of cultural factors.
KEY WORDS: Risk; management; deliberation; analysis

INTRODUCTION

provide a basis for forums for collaboration arising

from our similaritieswith tolerance and appreciation of our differences. We have attempted to use
three key questions to provide a lens to look at this:

As we enter the 2000s and debates about risks

take center stage with high profile issues like genetically modified organisms (GMOs), global climate
change, Y2K, and the natural resource burden of the
worlds consumption patterns, national differences
and similarities in how to manage these issues become more and more important. Clearly language
and culture will continue to present challenges to
those negotiating risk management solutions between nations. However, it is not widely appreciated
that the different methods that we use to identify, assess, and communicate about risks also may present
significant challenges. A look at these national variations is therefore particularly useful at this point in
time. Such an examination will provide insights to
further international risk management dialogues, and

What role does the public play in the risk

management process?
What role does risk analysis play?
What cultural factors will be important in
increased globalization of risks?
Here we focus on only three nations, Japan, Sweden,
and the United States, reflecting only developed
countries, but we hope that this effort constitutes a
beginning of a larger analysis.

WHAT ROLE DOES THE PUBLIC PLAY

IN THE RISK MANAGEMENT PROCESS?
In the United States, there has been considerable
evolution of the role of the public in risk management.
While risk management dialogues in the 1970s were often characterized as decide-announce-defend, with
one-way communication from decision makers to the
public (NRC, 1989), dialogues in the 1990s were designed to be multi-way, with stakeholders being brought
into the discussion prior to the final decision (Fischhoff,

Risk Research Group, Centre for Environmental Strategy, University of Surrey, Guildford, Surrey.
2
Institute of Policy and Planning Sciences, University of Tsukuba,
Ibaraki, Japan.
3
Harvard Center for Risk Analysis, Harvard School of Public
Health, Boston, MA.
*Address correspondence to Ragnar E. Lfstedt, Risk Research
Group, Centre for Environmental Strategy, University of Surrey,
Guildford, Surrey GU2 5HX, UK; rlofsted@surrey.ac.uk.

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0272-4332/00/0400-0157$16.00/1 2000 Society for Risk Analysis

158
1995; Leiss, 1996, NRC, 1989). Efforts to conduct comparative risk analyses have stimulated discussions about
how to identify stakeholders for issues of different
scales (particularly for national and global issues; Finkel
and Golding, 1994; Morgan et al., 1996). A recent report
by the U.S. National Academy of Sciences proposed the
use of an analyticdeliberative process for risk management that clearly emphasized the need for public participation in the process (NRC, 1996). While implementation of the analyticdeliberative process is in its infancy,
within the next decade risk assessors, risk managers, and
risk communicators will be expected to work with the
public and with each other in the definition of problems
and in the management of risks.
In Sweden, risk management decisions are taken
in two stages. The initial central government process
brings together state regulators, various government
agencies, trade unions, some affected stakeholders,
and industrial representatives to discuss managing a
risk. The outcome of this deliberation is then communicated by the regulator responsible to a wider constituency, and companies, municipalities, trade groups,
and private individuals are able to comment on the
proposed legislation. These inputs are then considered; the legislation may or may not be modified and
made into law. Aside from the consultation exercise
in which members of the general public rarely take
part, it is fair to say that the public to date has played
a peripheral role in the risk debates (Granberg and
von Sydow, 1998). The management of Swedens high
level radioactive waste, however, is an important exception, where referenda were held in the community
around planned storage facilities (Drottz-Sjberg,
1996, 1998; Sjberg, 1999). For the most part, policymakers have not historically found it useful or necessary to involve the public in the risk management
process; however, as in the United States, the government has started increasing public involvement. Including members of the public may help to build trust
(Lfstedt, 1999; Renn et al., 1995) and contribute toward more satisfactory outcomes (Renn, 1999). Pressure on the Swedish government to reassess the role
of public participation is also coming from international sources. Risk managers in other nations have
in recent years proclaimed the benefits of public involvement (NRC, 1996; RCEP, 1998), and some European Union (EU) policies (e.g., the Control of Major Accident Hazards [COMAH] directive) call for
greater public involvement in the risk management
process (Fairman et al., 1998).
In Japan, it was in the early 1990s that environmental managers began to shift away from the tradi-

Lfstedt, Ikeda, and Thompson

tional paternalistic approach of consensus-based regulation to the risk-based and preventive approach of
open and informed regulation. The Japanese traditional consensus-based regulation was based on informal and personal networks among stakeholders where
people in the street had to rely on the authorities decision making in the dichotomy of safety and danger to ensure no risk to human health (Ikeda, 1986;
Yokoyama, 1997). However, in the late 1980s, nationwide monitoring and surveillance systems revealed a
number of hazardous and carcinogenic chemicals in
relatively high concentrations in food crops, living organisms, and sediments in Japanese soil, forest, rivers,
lakes, and coastal areas. Then, the public began to
question what risks could be tolerated in exchange for
benefits, and what price could be paid for a safer environment in the days of low economic growth in 1990s.
It seems that this change in public attitudethough
not necessarily of the majoritytogether with the increased scientific and technological knowledge of the
complexity and uncertainty involved in environmental
problems, was the cornerstone for regulatory reform
in the late 1990s (Ikeda, 1998). This led to calls for a
formal public involvement in Japanese environmental
regulation in various ways, and urgent implementation
of Pollutant Release and Transfer Registry (PRTR;
Nakasugi, 1997). Typical recent examples of public involvement include disputes over the management of
dioxins from municipal waste incinerators, and the selection of sites for final disposal of industrial wastes.
Together these have accounted for over a hundred
public disputes on the Japanese islands in the past few
years. In addition, some communities have held referendums on the siting decisions for waste treatment facilities and nuclear power plants.

WHAT ROLE DOES RISK ANALYSIS PLAY?

In Japan, risk-based environmental regulation
shifted in the early 1990sas a part of the regulatory
reform of the so-called public nuisances to human
healthto an environmental preservation focus,
giving more emphasis to sustainability and recycling
waste. This environmental principle originated from
the revised Basic Environmental Plan (1994), which
called for no export of pollution to neighbors, future
generations, or other creatures in the ecosystem (Environment Agency Japan, 1994). This reform of environmental policy requires an extensive monitoring
scheme and research on potential environmental hazards and risks. One of the regulatory offices in the Environment Agency that formerly dealt with public

Perspectives
health issues such as contamination by heavy metals
(like mercury that caused Minamata Disease) was reorganized as the Office of Risk Assessment. In addition, risk analysis is increasingly being considered in
regulatory decision making in other governmental
organizations. In 1993, drinking water quality standards were added for fifteen chemical substances, following the World Health Organization (WHO) guidelines concerning carcinogenic risks, and over 20 air
pollutants were listed in the priority table of the 1996
amendment of the Air Pollution Control Law. Each
pollutant is to be assessed for its carcinogenic or noncarcinogenic toxicity in terms of an acceptable risk
level for human health, but not for the ecosystem.
This suggests that the Japanese are moving from dichotomous decision making (between safety and danger) toward risk-based decision making among the
various options regarding technological risks. However, this shift requires a sound social system of open
access to risk-related information. This was partly implemented in the 1995 law of Product Liability that
provides risk information on commercial products to
enable consumers to make an informed choice. How
to implement this requirement further in terms of efficiency, equity, and justice among stakeholders is now a
key question for Japanese risk analysis research.
In the United States, risk analysis continues to
play a critical role in many decisions. For example,
risk analysis is central to the process of operating a
nuclear facility and to regulatory decisions made
about hazardous waste sites. The methods and assumptions used in risk assessment have changed dramatically over the past several decades, particularly
as demands for better communication and transparency of assumptions have led to more scrutiny of the
assessments. A recent National Academy of Sciences
report emphasized the importance of recognizing
both science and judgment in risk assessment (NRC,
1994). Risk assessors and managers continue to struggle with issues related to socioeconomic, political,
and legal precedents as they move toward the new
paradigm of an analyticdeliberative process. One
particularly important feature of the U.S. risk management process is that legal requirements are not
parallel for all areas of risk. The decision criteria used
can vary a great deal both within and among agencies
(particularly with respect to whether and how technological feasibility, costs, and benefits of management alternatives are considered). The notion of recognizing trade-offs of risk (Graham and Weiner,
1995) as well as trade-offs of multiple attributes of the
decisions has fostered some demand for more cohe-

159
siveness and an overriding structure. However, such a
structure is not yet currently in place.
Risk analysis is central to the regulatory system in
Sweden as in many other EU countries. Unlike the
United States, however, and similar to other EU countries, the legal dimension plays a very limited role, and
the precautionary principle is an important feature in
risk management. However, Sweden does differ from
its EU counterparts in how risks are assessed. First, unlike many European countries, Sweden has, on the
whole, higher regulatory standards than those proposed by the EU, and little regulatory action is typically needed when a new EU directive is passed (Ruden
et al., 1998). Second, the legal responsibility for worker
safety and the protection of the environment lies in the
hands of industry (i.e., companies have to prove to the
government that a certain product or process is safe,
usually by invoking a form of risk analysis). The regulatory body can accept or reject this assessment. However, this policy runs counter to the EU regulatory line,
and increasingly, Swedish regulators have taken greater
responsibility in proving whether a material is safe
or not (this is particularly true for chemicals). Third,
Sweden has long adopted a policy of reducing chemical risks by limiting availability, taking the view that if
the chemical is not available the risk is not either. This,
too, is changing with Swedens membership in the EU.
EU law stipulates that substances approved by
the EU should also be approved by member states.
To date, Sweden has faced difficulty in being granted
exceptions to this rule (Johannesson and Hansson,
1996; OECD, 1999; Ruden et al., 1998; Swedish State
Studies, 1998).

WHAT CULTURAL FACTORS WILL BE

IMPORTANT IN INCREASED
GLOBALIZATION OF RISKS?
In Sweden, two cultural factors appear to dominate in the discussion of globalized risks: the relatively high degree of the publics and regulators environmental, health, and social concerns (Bennulf,
1996; Ruden et al., 1998), and Swedish industrys already high levels of integration into the global economy. Swedish risk legislation is among the strictest in
Europe, and there is a growing public concern that
implementing EU laws will weaken Swedish regulation. The government is taking steps along with other,
more environmentally-friendly European nations, to
enable its stricter regulations to remain in place. Globalization, it is argued, could lead to imports of prod-

160
ucts that have not met Swedish standards (for example, meat and poultry products imported to Sweden
may not meet the countrys very low salmonella contamination thresholds) and at the same time hamper
exports, as regulations may increase costs. However,
these views contrast with those of the Swedish multinational corporations who are largely in favor of globalization. These corporations see it as a market opportunity and argue that exporting more products to
a larger number of markets can only help Sweden,
and that although strict regulations will lead to added
costs for the goods they produce, consumers will see
them as environmentally friendly and pay the added
price (Vogel, 1995). As Sweden has more multinational corporations per capita than any other
nation in the world, this view may weigh heavily on
how Swedish policymakers respond to the risks of
globalization. In sum, the jury is still out on whether
globalization on the whole will be viewed as good or
bad for Swedish consumers.
In the United States, economic and political issues can drive public policy choices in some cases, but
clearly the United States is a strong supporter of globalization and free trade. Generally, Americans are
inclined to want to see scientific proof before taking
action, or at least to have a compelling enough case
(e.g., Food and Drug Administration requirements
related to pharmaceuticals). However, the stakes in a
decision play a role in what it takes for evidence to be
compelling in the United States, and opportunities
to reduce uncertainties by collecting better information may be recognized before final decisions are
made. With respect to the precautionary principle,
this is a relatively new concept in the United States
and one that is still being defined (Graham, in press).
However, given the complex balance of power between the government, industry, nongovernmental
organizations (NGOs), and individual citizens, risk
analysis is likely to play a major role in what is viewed
as precautionary and what is not. As a democracy
with a free press, risk issues can take on a life of their
own. In the United States, the Internet and laws requiring disclosure of information are changing how
risk issues impact politics, culture, and the economy.
In Japan, the shortage of risk studies on scientific
evidence, including epidemiological surveys, has
forced most Japanese regulatory measures to follow
WHO, Organization for Economic Co-operation and
Development (OECD), International Atomic Energy Agency (IAEA), or United States guidelines.
Both international harmonization and the need for a
scientific base have been used to excuse the lack of

Lfstedt, Ikeda, and Thompson

cultural, environmental, and ethical considerations in
setting regulatory guidelines in the case of globalization of risks. This leads to some confusion for regulatory authorities as they discuss standards with the
public and the mass media, and in other communication channels. It is often seen in the disputes about dioxin risks that there is little common understanding
about the nature of risk, exposure to the endpoints,
uncertainty of risk measures, and abatement options
among authorities, experts, the public, and with other
countries. We see the same issues in the recent dispute about labeling GMO soybean products imported into Japan in terms of international trade harmonization and the cultural tradition of food safety.
The increased awareness of technologically induced
risks and the societal demands for shaping common
understanding of risk analysis will create an opportunity of developing risk communication as one of the
most important policy means in the risk-based approach in Japan (Hirose, 1999). Defining risk communication as an interactive process of exchange of information and opinion among individuals, groups, and
institutions (NRC, 1989) is also expected to be extended in some way to accommodate differences of
life-style or living standards in a multitude of societies.

CONCLUSIONS AND OBSERVATIONS:

WHAT DO WE LEARN?
It is clear that deliberative risk management processes are gaining in popularity in all three countries.
This may be due to a variety of factors including lack
of public trust toward government officials and regulators, greater availability of information, the acknowledgement that the public and stakeholders can
add a new dimension to risk management, or possibly
due to the so called export of risk policy (i.e., if the
Americans and the British are doing it, we better all
do it, too).
It is interesting to note how influential American
research and practice in the area of risk analysis has
been globally to date. Japan did not start using formal
risk-based approaches until the early 1990s, and most
of the assessments conducted on products by Swedish
industry have been based on earlier U.S. work. A key
issue for the future will be ensuring that international
commitments are made to risk-related research and
policy development.
Globalization is also beginning to impact risk
management decision making in all three countries,
but it is unclear how great the impacts will be ulti-

Perspectives
mately, and whether global criteria will emerge, or be
viewed as incompatible with national interests. The
EUU.S. debate over the use of the precautionary
principle will be influential. Clearly there will be no
shortage of risk analysis research questions for the future. Our hope is that research in the new millennium
will help shed light on international differences and
offer global risk strategies that are beneficial to us all.
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