Special Policy Study Report: Eco-environmental Risk Management

Rapport 2015/

Haakon Vennemo

Special Policy Study Report: Eco-environmental Risk Management

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China Council for International Cooperation on Environment and 	
Development (CCICED)	 	
 
 
 
 	
 	
 	
Special Policy Study	 Report	 	
 	
Eco	-environmental Risk Management	 	
 
 
 
 
 
 
 
 
 
 
 	
CCICED 2014	 Annual General Meeting	 	
November 9	-11, 2015

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Special Policy Study Members	 	
 
Co	-chairs	* 	
Jun Bi	 	Dean	 and	 Professor, School of the Environment, Nanjing 	
University	, Changjiang	 Scholar of Ministry of Education	 	
 
George Greene	 	Senior	 	Associate	, 	International Institute for Sustainable 	
Development	; Founding Chair of Stratos Inc.	 	
 
Consultant	s 	
Jiuhui Qu	 	Academician of Chinese Aca	demy of Engineering	, Professor	 of 	
Research Center	 	for Eco	-environmental Sciences, Chinese 	
Academy of Sciences	 	
 
Kaiyu Wang	 	Deputy Director, Department of Science, 	Technology	 and 	
Standards	, Ministry of Environmental Protection	 	
 
Jinnan Wang	 	Professor, 	Vice	 President and 	Chief 	Engineer of	 Chinese	 Academy	 	
for Environmental Planning	 	
 
Stephen Andrews	 	Senior Vice President and Head of Environmental 	EMEA	 Region, 	
American 	International 	Group	 	
 
Key Experts	 	
Chinese Team	 	
Shi	qiu Zhang	 	Professor, College of Environmental Sciences and Engineering, 
Peking University	 	
 
Jinliang Zhang	 	Professor, Chinese Research Academy of Environmental Sciences	 	
 
Fang	 Yu	 	Professor, Chinese Academy for Environmental Planning	 	
 
International Team	 	
Haakon Vennemo	 	Partner and Senior Researcher, Vista Analyse AS; Adjunct 
Professor, Oslo 	Business	 School (HIOA)	 	
 
Jonathan Wiener	 	Professor of Law and Professor of Public Policy and 
Environmental Policy, Duke University

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Ortwin Renn	 	Professor	 	for Environmental Sociology and Technology 	
Assessment, University of Stuttgart	 	
 
Support Team	 	
Hongguang Cheng	 Professor, School of Environment, Beijing Normal University	 	
 
Cun	kuan Bao	 	Professor, Department of Environmental Science and Engineering, 
Fudan University	 	
 
Weihua Zeng	 	Professor, School of Environment, Beijing Normal University	 	
 
Qingwei Guo	 	Professor, South	 China Institute of Environmental Sciences, MEP	 	
 
Yu Qian	 	Professor, School of the Environment, Nanjing University	 	
 
Changsheng Qu	 	Associate Professor, Jiangsu Provincial Academy of 
Environmental Science	 	
 
Wei Zhang	 	Ph.D., Chinese Academy for Environmental Pl	anning	 	
 
Zongwei Ma 	 	Ph.D., School of Environment, Nanjing University	 	
 
Miaomiao Liu	 	Ph.D., School of Environment, Nanjing University	 	
 
Coordinators	 	
Zongwei Ma, 	 	Ph.D., School of Environment, Nanjing University	 	
 
Peishen	 Wang	 	Consultant, former Senior Environmental Specialist of 	the World 	
Bank	 	
 
* Co	-chairs and 	Special 	Policy 	Study M	embers serve in their personal capacities.	 	
 Chi	nese Co	-chair and Study Members led report drafting; 	Chapter 3 	describing 	
international experiences was drafted by international members; Chinese and 
International Co	-chair and Study Team Members contributed to and reviewed the 	
report at each stage	.

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Background of the Study	 	
 
Rapid socioeconomic development coupled with 	constraints	 on resources	, pollution	, 	
and ecological degradation	 have	 already 	ha	d significant impacts on public health, public 	
safety	, and social stability	 in China	. During 2016	-2020 and the	 implementation of	 the 	
13	th Five	-year Plan (FYP), China will be cha	racterized by slowing economic 	growth	, 	
continued industrialization	, increased use of 	natural	 resources, structural adjustment, 	
urbanization, and social transformation. Environmental management will be more 
complicated and unpredictable, with pressures 	comi	ng 	from 	rapid 	socioeconomic 	
development and 	strong public 	demand	s for	 environ	mental quality.	 	
During this period, environmental risks	1 will be more serious. China has 	already 	
endured 	frequent environmental accidents	 and high levels of chronic exposure	 to 	
pollution. Environmental risks affecting public safety, human health	, 	and 	
environmental and ecosystem 	quality continue to be evident. 	Meanwhile, p	ublic 	
demand for a safe environment is 	intense and growing	. 	Data from 	the 	China 	
Environmental Yearbook	 show 	that the 	number 	of environmental petitions and 	
complaints 	increased more than 	20	-30% 	annually 	in recent years. 	Public protests 	
against environmental issues 	and 	events continue to occur.	 	
In the face of serious environmental risks and the politically importa	nt task of 	
constructing 	ecological civilization	, the 2011 statement 	Opinions on Strengthening 	
Major Environmental Protection Tasks by the State Council	 for the first time mentioned 	
“risk prevention” in a national policy document. At the same time, 	China’s 	Ministry for 	
Environmental Protection (	MEP	) introduced a three	-stage strategy called "reducing 	
total amount 	of pollutants, improving environmental quality	, and preventing 	
environmental risk" in the 12	th Five	-year Environmental Planning Guideline. Risk 	
prevention was also clearly included in China's environmental management strategy for 
the first time, indicating that the development of a risk prevention and management 
system had become an important part of buil	ding a new roadmap 	for	 the protection of 	
China's environment and 	the construction of 	ecological civilization.	 	
Opinions of the Central Committee of the Communist Party of China and the State 
Council on Further Promotin	g the Development of Ecological 	Civili	zation	, issued in 	
2015	, maintain	s the basic state policies of 	conserving 	resources and protecting 	the 	
environment	. It puts	 the 	development of 	ecological civilization 	in a prominent strategic 	
place	 that is 	incorporated into the whole process 	of 	economic, 	political, cultural, and 	
social development	. In the same year, t	he Central Committee of the Communist Party 	
of China and the State Council	 issued the	 Integrated Reform Plan for Promoting 	
Ecological Civilization System	 to accelerate the establishment of a c	omplete e	cological 	
civilization 	system	 and 	to 	promote the construction of e	cological 	civilization	. The 	
National	 Security Law of China	, implemented in 	2015	 has incorporated e	nvironmental 	
safety into the national security system	. 	
The 	Third 	Plenary 	Session of 	the 	18	th Communist 	Party of 	China	 Central Committee 	
(Third Plenary) 	clearly pointed out that	 building 	ecological civilization requires	: 	
 	 	 	
1 The term “	environmental 	risk” in this 	report includes ecological risks.

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establishing a comprehensive ecological civilization system	; implementing 	rigoro	us	 	
protection from 	the sources of 	environmental risk	; compensating for 	damage	; liability 	
systems	; and	, improving the environmental governance system and the ecological 	
restoration system. 	Compared 	with 	other 	environmental regulat	ions	 and control	s, 	
China’s 	environmental risk 	management	 system	 is seriously lacking	 in terms of	 	
effective	 strategy, institutions, policies, and technologies. 	Environmental risk issues 	
have	 posed	 great challenge	s for 	the construction of 	ecological civilization in China.	 	
Studies are urgently needed 	to help build a series of effective 	and efficient	 	
environmental 	risk 	management	 policies and 	systems	. 	
To explore the construction of 	an 	environment	al risk management system 	and 	to 	
provide policy recommendations for transforming environmental 	policy 	toward	 an	 	
environmental risk 	management mode, the 	China Council for International Cooperation 	
on Environment and Development (CCICED)	 organized a team of domestic and foreign 	
experts	 to conduct the	 special policy study (SPS) 	on 	“Eco	-environmental Risk 	
Management”	, with t	he School of the Environment at Nanjing University 	as the	 lead	 	
Chinese institution	. 	
The project was launched in April 2015. 	The 	project 	team has studied the current 	
situation and future 	prospects 	for 	environmental	 risks in China, reviewed 	China’s 	
en	vironmental risk management system and analyzed its problems, and summarized 	
international experiences on environmental risk management. Th	is analysis	 underpin	s 	
the 	policy recommendations for an environmental risk management system in China. 	 	
Th	e team held three working meetings to integrate comments and 	suggest	ions from 	
Chinese and international experts. Th	is project report and 	its 	policy recommendations 	
have been 	developed 	on the basis of 	joint efforts of 	these 	team members. 	We 	expect 	
that this	 study 	will 	support the 	build	ing	 of 	a robust environmental risk management 	
system	 in China	.

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Summary of Key Findings	 	
 
1. China’s 	Environmental Risk Situation is 	Serious	 	
The 	2005 water pollution accident at the 	Songhua River	, Jilin province,	 triggered 	initial 	
efforts 	to 	construct 	an 	environmental risk management system in China. Since then	 	
China has paid more attention to environmental risk	 management.	 Although t	he 	
frequency of a	ccident	al pollution 	events 	has 	decreas	ed,	 they 	still 	occur often. 	MEP 	
reported 712 and 471 environmental accidents for 2013 and 2014 respectively.	 Serious 	
environmental accidents continue to happen, such as the 	Dalian oil pipeline explosion 	
in 201	0 and 	the 	Tianjin 	hazardous chemical	s explosion 	in 2015	. 	
Meanwhile, 	China is becoming more aware of 	long	-term chronic risks 	such as 	PM	2.5	 	
air 	pollution	 and contaminat	ed sites	. PM	2.5	 has become the fourth 	highest	 mortality risk 	
factor in China	. A	ccording to Global Burden of Disease data	, it caused 	approximately	 	
1.23 million premature death	s in 2010	. 	
At the same time	, as public demand for environmental protection rise	s, the level of 	
environmental risk that the public will accept 	is 	decreas	ing	. T	he 	number	 of 	
environmental petitions and complaints 	has 	grown at 	an annual rate of 	20	-30% in recent 	
years	. This	 is a new characteristic of environmental risk 	that is 	emerging in China	. The 	
gap between 	actual	 and 	publicly desired 	environmental risk levels 	is 	growing	, which 	
suggests	 that 	the current situation of 	environmental risk is serious	 and requires attention.	 	
2. 	Current 	Environment 	M	anagement 	System 	Cannot 	M	eet the 	Demands 	for	 	
Environmental 	Risk 	Prevention and 	Control	 	
The 18th National Congress of the Communist Party of China (CPC) 	introduced 	the	 	
goal 	of 	building a moderately prosperous society 	by	 2020 and incorporat	ing	 ecological 	
civilization into the overall 	design 	of 	socialism with Chinese characteristics	. During the 	
critical period of completing the building of a moderately prosperous society, 	under 	
cu	rrent condition	s many environmental risks 	remain 	that	 need to be reduced and 	
controlled more effectively	. The 	gap between 	current	 environmental risk levels and 	
public 	risk perception	 has 	become a major restraining factor. 	The	 National	 Security 	
Law of China	, implemented in 	2015	, notes the need 	“to 	strengthen	 the early warning, 	
prevention, and control of ecological risk	, and to 	address	 accidental	 environmental 	
incidents properly	.” Environmental	 safety 	thus is being recognized as part of	 the 	
national security system	. 	
Environmental risk management in China	, however, 	is still in its 	early 	stage	s; that is, it 	
is in 	an	 “event	-driven	, environmental 	response	” mode. 	The	 en	vironmental risk 	
management system is incomplete, 	and it 	cannot 	yet 	meet 	the	 increasing	 public 	
demands 	for	 eco	-environmental safety and the needs of 	national security.	 	
(1) 	The 	environmental risk governance system is incomplete. 	A 	comprehensive	 	
environmental risk	-based decision	-making system has not been 	well 	formed. 	
Environment	al 	risk assessment has not been comprehensively and substantially 	
incorporated into	 major	 national strategies and plans	 (such as the 	Five	-year Plans, 	new	-

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type urbanization, 	integrated development of 	the 	Jing	-Jin	-Ji area, 	the 	Belt and Road 	
initiative, and 	the 	Yan	gtze River Delta economic zone),	 or into 	spatial 	planning 	
decisions 	or 	project environmental impact assessments (	EIA	). Further	more	, China lacks 	
a neutral 	institution to provide scientific environmental risk assessment	s for national 	
decision making, 	and it lacks 	a high	-level body 	to 	guide 	and oversee the environmental 	
risk management 	system	. Vertical and horizontal 	fragmentation 	across government 	
departments and agencies 	in environmental management 	undermine efforts 	to address 	
the 	many 	environmental risks 	facing	 China.	 	
(2) The basis for environmental risk decision making is incomplete. 	Systematic 	
environmental risk management goal	s and 	a national 	strategy 	and 	system 	for managing 	
environmental risks 	ha	ve	 not been 	established	. The current 	situation and 	prospects 	for 	
control of	 environmental risks in China 	remain 	unclear. 	China lacks 	comprehensive and 	
integrated national environmental risk analysis, assessment, and ranking	 to set priorities 	
for risk management	, and to shape 	environmental 	risk management goals and strateg	ies	. 	
The	re are no clear or systematically derived	 management priorities 	for	 environmental 	
risks	 or 	for selecting appropriate risk reduction strategies and measures	. Meanwhile	, 	
China lacks 	research on the mechanisms 	through 	which 	environmental risks induce 	
other risks	, such as 	those 	related 	to 	social stability, economic security, and national and 	
regional securit	y. The analysis of comparative costs and benefits has not been well 	
incorporated into actions and policies to 	reduce environmental risk.	 	
(3) The	 set of 	enabling 	measures 	for environmental risk reduction 	is incomplete. 	For 	
example, China lacks 	a 	unified	 environmental risk information database and data 	
shar	ing 	system.	 The system of e	nvironmental law	s and regulation	s to prevent and 	
control risks is	 incomplete. 	The establishment of an e	nvironmental judiciary is still at 	
the	 initial stage. 	Economic and	 financial instruments for environmental risk 	
management	 are insufficient	. The capacity for e	nvironmental risk emergenc	y response 	
is weak. 	Finally, 	responsibility on the part of 	industry and 	state 	enterprise 	for 	
environmental risk control is	 seriously 	lacking	. Environment, health, and safety (EHS) 	
management systems have not been established in most of the enterprises. 	 	
(4) The environmental risk communication system is incomplete. 	While a	 preliminary 	
environmental information disclosure and public engagement system has been 
established	, there 	remains	 a lack of 	enabling 	and opera	ting	 policies and regulations	 to 	
guide information disclosure and public engagement 	in an 	orderly	 and sufficient 	
manner	. Both 	environmental information disclosure and public engagement 	are poorly 	
implemented and ineffective	. The environmental risk communication system is 	
incomplete	 an	d 	incapable of meeting 	the needs 	for informing	 or eliciting	 public 	
perception	 and understanding of environmental risks.	 	
Driven by economic growth	, industrialization	, and other factors, environmental risk 	
pressures 	in China 	will keep increasing in the 	immediate and long	-term future	, unless 	
policies change these trends	. Meanwhile, rising incomes and education will tend to 	
promote greater public desire for protection against environmental risks. A	nd, 	driven 	
by the need to manage various environmental risk	 sources, risk management levels will 	
improve over time with better policies and controls in place. It is expected that the 
increasing levels of environmental risk management 	combined with 	progress in 	the 	
science and technology	 of environmental protection	 will offset the increments of 	
environmental risk to some extent. But 	these 	risk	s may still not attain the levels needed 	
to protect environmental quality, ecosystems	, and human safety to 	the degree needed to

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meet 	the 	public	’s willingness to accept	 these ris	ks.	 The environmental risk situation 	
therefore 	needs more attention to cope with present and 	future	 challenges	. In other 	
words, the e	nvironmental risk management 	system 	needs to be strengthened.	 	
3. 	The 	Environmental 	Risk 	M	anagement 	System in China 	Still 	Lag	s Behind Other 	
Countries	 	
Countries	 in Europe and 	North 	America	 and parts of Asia	 which 	have established 	
relatively 	robust and 	efficient	 environmental risk management systems:	 	
(1) These countries have established e	nvironmental risk governance systems at 	macro 	
levels.	 They have incorporated e	nvironmental risk issues into national decision	-making 	
system	s. 	A number of	 decision	-making process	es in these countries	 apply	 	
environmental risk assessment	 ─ with	 risk 	priority	-setting	 ─ to 	maximiz	e social well	-	
being by 	adopting risk management measures that 	attain	 benefits 	justify	ing	 the	 costs. 	
Institutions	 such as 	regulatory oversight bod	ies or 	environmental risk board	s guide 	the 	
work of 	ministries and agencies	 in these 	count	ries	. 	
(2) 	A system of 	differentiated 	environmental r	isk management goals	 ha	s been 	
established	 for different 	types of risks	 and for	 different ind	ustries. Some of these risk 	
goals are	 quantitative and 	some	 qualitative	, using science	-based risk assessment and 	
incorporating levels of public concern and 	the 	cost	-effectiveness of control measures.	 	
(3) Environmental risk enabling systems 	which are relatively complete 	have been 	
formed, including 	monitoring and data collectio	n, 	effective 	law	s and regulatio	ns, 	
compliance enforcement, economic and 	financial instruments, and industry and 	
enterprise responsibility	 systems.	 	
(4) 	These countries have established i	nstitutionalized and e	ffective environmental risk 	
communication and 	orderly 	public engagement systems to 	inform the public and to 	
elicit public preferences. These systems can help 	address the 	gap	s between public 	
perception	s and 	actual 	risk levels, which may affect 	confidence and trust 	among 	
governments	, citizens	, and othe	r stakeholders.	 Nonetheless	, public perceptions can 	
misjudge risks, sometimes overstating and sometimes understating	 them	. 	
Compared with countries in Europe and 	North 	America, 	and increasingly in south	-east 	
Asia, 	environmental risk management systems in 	China still lag	 behind	. International 	
experiences can provide 	good 	benchmarks 	for building 	a successful 	environmental risk 	
management system in China.	 Looking ahead,	 China could be	come	 a leader in creating 	
new, state	-of	-the	-art systems for environmental 	risk management, learning from and 	
innovating beyond past approaches in other countries.	 	
4. 	Building 	a Robust	 and Complete 	Environmental 	Risk 	M	anagement 	System is 	
Urgently 	Needed 	to Support the Transformation of Environmental Management 	 	
There is an urgent	 need to	 improve the environmental risk situation	 in China	, to reduce 	
environmental risk levels 	and improve the control of environmental risks	 more 	
effectively	, to 	reduce 	the gap between 	actual 	environmental 	risk levels and 	the 	public 	
desire for greater protection at lower risk 	levels, and 	to 	protect national security	. Hence,	 	
there 	is an 	urgent need to transform 	China	’s environmental 	risk 	management 	mode from 	
pollution control 	and quality improvement 	to 	fully integrate 	risk prevention and

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reduction	. This	 environmental risk	-based	 management system	 will	 form the 	foundation 	
for the prevention and mitigation of environmental risks, 	and 	trigger 	effective response	s 	
to restor	e the consequences of environmental risks.	 	
Based on 	analyses	 of 	the 	current status and 	future 	prospects 	of 	environmental 	risks	 in 	
China	, the 	status 	of 	and demands o	n its 	environmental risk management system, and 	
inspired by 	international experience, this study	 proposes policy recommendations for 	
building an effective 	environmental risk management system in China 	through a 	
strategy comprising 	four 	areas:	 environmental risk governance	; risk 	goals and strategies	; 	
enabling measures	; and environmental risk communication and engagement	. These 	
recommenda	tions are intended to 	provide 	a foundation 	for the transformation of 	the 	
environmental 	risk 	management 	system	 in China	.

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Summary of Main Policy Recommendations	 	
 
Recommendation 1. Establish 	a Risk	-based 	Environmental 	Governance 	System	 	
(1) Establish a	 high	-level	, permanent National Environmental Risk Board. 	The 	
responsibilities of the Environmental Risk Board are to 	identify, 	assess	, and prioritize 	
current and potential 	future	 environmental risks	 ─ 	for the	 three categories of risk: 1) 	
sudden accidental	 risks	, 2) 	cumulative threshold	 risk	, and 	3) 	long	-term chronic 	
risks	; to help resolve	 tradeoffs 	among multiple risks, and 	between economic 	
development goals and environmental risk control; and, to 	co	ordinate	 and	 oversee 	
environmental risk management 	issues across relevant government departments	 in an 	
integrated way	, ensur	ing	 environmental risk assessments for major national economic, 	
legal, and environmental decision making	. 	
(2) Establish 	a comprehensive 	environmental risk	-based decision making system.	 	
Launch 	an	 environmental risk assessment and prevention system for 	the 	macro	-	
strategies of China's national modernization process. 	Carry out short	-term, middle	-term 	
and long	-term environmental r	isk assessment	s for national macro	-strategies such as 	
new	-type urbanization, integrated development of 	the 	Jing	-Jin	-Ji area, 	the 	Belt and 	
Road initiative, and 	the 	Yangtze River Delta economic zone, and develop effective 	
environmental risk prevention 	roadmaps	 for these strategies	. Incorporate environmental 	
risk assessment process	es	 and risk management into government decisions at every 	
level of policy, sector, regional	, and 	urban planning, and 	major construction projects	 	
that have a potential to affect	 human heath, environmental quality, and ecosystem 	
integrity	, and 	for 	the 	development of environmental standards	. Integrate 	multiple 	
spatial plans	, including e	conomic and social development plan	s, urban and rural plan	s, 	
land use plan	s, 	and 	ecological 	protection plan	s into one plan, incorporating 	
environmental risk assessment. 	Integrate environmental risk assessment, environmental 	
impact assessment, and social 	stability risk assessment	 to create	 synergy	 across multiple 	
assessments	. 	
(3) 	Rearrange 	enviro	nmental risk	-based institution	s and function	s. Establish MEP 	
departments for air, water, 	and 	soil to enable a coherent system of authority and 	
responsibility for 	supervision 	of major environmental risks	, and 	build in specific 	
coordination mechanisms across	 the new departments to avoid problems of 	
fragmentation	; strengthen vertical authority and coordination of MEP 	with	 provincial	 	
environmental protection bureaus	. Strengthen 	regional Environmental Supervision 	
Centres with oversight 	by	 the National Environmen	tal Risk Board	. Reform the 	
management system 	for	 dangerous chemicals which 	currently 	involves multiple 	
departments. Clarify the main body of regulation	. Incorporate chemical	s management 	
into the current environmental emergency response system	. 	
Recommendation 2. Establish 	Environmental 	Risk 	M	anagement 	Goal	s and 	
Strategy	 	
(1) Set environmental risk management target	s. 	Set comprehensive 	national 	
environmental risk reduction and minimization	 goals and	 target	s incorporating	 the 	
national development strategy,	 the 	results of 	a national 	environmental 	risk assessment,

x 	
the 	costs	 and benefits	 of risk control, and 	the 	public perception of risks. 	Require 	
provinces	, cities	, and 	regions to prepare roadmap	s setting out 	the pace and pat	h to meet 	
the target	s, based on regional environmental risks,	 natural	 environmental	 conditions, 	
economic and social conditions	, and 	regional development strateg	ies	. 	
(2) Establish a 	comprehensive 	national environmental risk management strategy. 	
Conduct a 	comprehensive	, systematic	 national assessment to set national and regional 	
risk priorities	 for the three categories of environmental risks	. Based on the assessment 	
results, develop and apply an 	environmental risk	 chain	-based	 management	 approach 	
emphasizing	 	risk avoidance and prevention, and risk response, mitigation, 	
compensation	, and remediation where necessary, to reduce overall risks and yield 	
health, environmental quality	, and ecosystem benefits that justify the costs.	 	
Recommendation 3. Establish 	Enabl	ing 	M	easures for 	Environmental 	Risk 	
M	anagement	 	
(1) 	Complete 	legislation and 	a judiciary for environmental risk management. 	With 	
the goal of 	establishing 	a whole	-process	 approach for the	 prevention and 	reduction 	of 	
environmental risk	s, improve laws and 	regulations	 for environmental protection. 	Put in 	
place a 	soil environmental protection law, 	and 	establish supporting laws and regulations 	
for legacy 	(historical) 	contaminated site	s management. 	Develop	 a Dangerous 	
Chemicals Safety and Environmental Risk Law	 that applies to all dangerous chemicals	 	
based on the existing 	Hazardous Chemical Safety Management Regulation	. Implement 	
life	-cycle risk management for chemicals	, and strengthen comprehensive supervision	 	
and regulation	 of priority pollutants in industrial	 production	. Develop an 	Environmental 	
Liability Law	. Promote	 an 	environmental judiciary to 	support the 	control 	of 	
environmental risks.	 	
(2) Enable environmental risk information integration and sharing. 	Systematically	 	
integrate	 the 	environmental risk 	information	 that currently is 	distributed across multiple 	
departments 	and levels of government	 by building on the new 	Construction Plan for an 	
Eco	-environmental Monitoring Network	 to incorporat	e environmental risk information 	
into the national unified environmental info	rmation platform	. Conduct research to fill 	
information gaps 	(for example, 	exposure	 data and dose response functions for 	
ecosystem and human health	) and share these data via 	the 	Internet	. 	
 (3) 	Apply	 	financial 	and economic 	instruments	 	to prevent 	and reduce 	
environmental risks	. Develop and use financial 	and economic 	instruments for 	
environmental risk control	. Establish 	an 	environmental risk assessment	-based 	
enterprise financial 	secu	rity	 system	 for sudden and accumulative environmental risks	. 	
This should include	 mandatory	 liability insurance for industries and enterprises	, an 	
environmental risk deposit system for high	-risk industries	, and	 special funds for 	
contaminated site 	remediation and environmental health compensation	. Economic 	
measures such as market based regulation also should be used to prevent and reduce 
environmental risks.	 	
(4) 	Establish a collaborative multi	-department environmental emergency 	
response system with 	practical emergency response plan	s as 	a core requirement	. 	
Improve the effectiveness of all levels and all kinds of environmental emergency 
response plans	. E	stablish j	oint emergency response mechanism	s with clear 	authority	, 	
responsibility	, and information sharing	, involving government departments 	for 	safety

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supervision	, transportation, environmental protection, and 	public security	. O	ptimiz	e the	 	
allocation	 of regional environmental emergency resource	s. 	
(5) 	Clarify, support and enforce the pr	imary responsibility for environmental risk 	
prevention and 	control on the part of enterpris	es. 	Establish clear responsibilities	 for	 	
response and remediation 	by 	industries and 	state and other 	enterprises for	 accidental 	
and	 legacy risks	. Drive and support industry sectors and 	state and other 	enterprises to 	
be responsible for adopting environmental risk management practices through 
government	-enterprise cooperation, including	 punitive and incentive measures	, and 	
training. R	equire 	that 	ente	rprises 	establish	 environment, 	health, and 	safety	 (EHS) 	
management 	system	s. Put in place rules for 	mandatory 	environmental risk disclosure in 	
financial reporting requirements of the China Securities Regulatory Commission	, and 	
gradually establish the green 	credit system	 with an emphasis on 	risk 	prevention	. 	
Recommendation 4. Establish 	an 	Environmental 	Risk 	Communication and 	
Engagement 	System	 	
(1) 	Develop a transparent and effective environmental risk communication	 system. 	
Launch 	data	-sharing and disclosure	 mechanism	s for multi	-source 	environmental risk 	
information 	(including risk sources	 and 	assessment	, regular environmental monitoring, 	
environmental emergency response	, and public perception information)	 across national 	
ministries and 	with 	local, regional	, and provincial 	environmental	 protection bureaus	. 	
Using measures such as information transfer, round	-table conferences, and community 	
engagement	, d	evelop 	a multi	-dimensional 	and transparent environmental risk 	
communication and engagement system involving mu	ltiple stakeholders	, including 	
government departments, enterprises, 	the public, 	media, and social organizations	. 	
Establish mechanisms for risk knowledge transfer to and from the public	. 	
(2) Establish 	an 	efficient environmental risk engagement 	program	s. Develop 	and 	
implement 	community and public engagement models for dialogue and feedback from 	
affected communities. 	Promote public participation in 	strategic and 	environmental 	
impact assessments of 	polic	ies	, spatial	 planning, and project	s. Involve 	social	 	
organizations and community groups to 	help 	co	-design 	or evaluate 	environmental risk 	
management 	policies.

xii 	
Contents	 	
 
SPECIAL POLICY STUDY	 MEMBERS	 ................................	................................	............................	 I 	
BACKGROUND OF THE ST	UDY	 ................................	................................	................................	... III	 	
SU	MMARY OF KEY FINDING	S ................................	................................	................................	.......	 V 	
SUMMARY OF MAIN POLI	CY RECOMMENDATIONS	 ................................	............................	IX	 	
CHAPTER 1. CURRENT S	TATUS AND FUTURE PRO	SPECTS OF ENVIRONMEN	TAL 	
RISKS IN CHINA	 ................................	................................	................................	................................	.. 1 	
1.1	 DEFINITION OF 	ENVIRONMENTAL 	RISK	 ................................	................................	...........................	 1 	
1.1.1 Concept of Environmental Risk	................................	................................	...............................	 1 	
1.1.2 Environmental Risk System and Environmental Risk Chain	 ................................	...................	 1 	
1.1.3 Determination of Categories and Scope of Environmental Risks	 ................................	...........	 2 	
1.2	 CURRENT 	STATUS OF 	ENVIRONMENTAL 	RISKS IN 	CHINA	 ................................	................................	 3 	
1.2.1 Sp	ati	al and T	emporal Characteristics of Environmental Risks in China	 ...............................	 3 	
1.2.2 Current Situation of Public Perceptions o	f Environmental Risks in China	 ..........................	 11 	
1.2.3 Current Environmental Risk Levels in China	 ................................	................................	.......	 12 	
1.3	 PROSPECTS FOR 	ENVIRONMEN	TAL 	RISKS IN 	CHINA	 ................................	................................	......	 13 	
1.3.1 Overall Prospects 	for	 Environmental Risk Levels in China	................................	..................	 13 	
1.3.2 A Preliminary Scan of Environmental Risks in the Short and 	Medium	 Term	 Future	 ...........	 16 	
1.4	 PRINCIPLES OF 	ENVIRONMENTAL 	RISK 	MANAGEMENT	 ................................	................................	. 17 	
CHAPTER 2. CURRENT 	STATUS AND DEMANDS O	F ENVIRONMENTAL RISK	 	
MANAGEMENT SYSTEM	S IN CHINA	 ................................	................................	...........................	 19 	
2.1	 URGENCY OF 	ENVIRONMENTAL 	RISK 	MANAGEMENT 	SYSTEM 	CONSTR	UCTION IN 	CHINA	 ............	 19 	
2.2	 INCOMPLETE 	ENVIRONMENTAL 	RISK 	GOVERNANCE 	SYSTEM IN 	CHINA	 ................................	.......	 20 	
2.3	 LACK OF 	ENVIRONMENTAL 	RISK 	MANAGEMENT 	GOALS AND 	STRATEGIES	 ................................	.. 21 	
2.4	 INSUFFICIENT 	ENABLING 	MEASURES 	SYSTEM FOR 	ENVIRONMENTAL 	RISK 	MANAGEMENT	 ..........	 23 	
2.5	 WEAK 	ENVIRONMENTAL 	RISK 	COMMUNICATION AND 	ENGAGEMENT 	SYSTEM	 ............................	 26 	
CHAPTER 3. INTERNATI	ONAL EXPERIENCES OF 	ENVIRONMENTAL RISK 	
MANAGEME	NT	 ................................	................................	................................	................................	.. 28 	
3.1	 THE HISTORY OF ENVIRO	NMENTAL RISK MANAGEM	ENT SYSTEMS IN DEVEL	OPED COUNTRIES	 ......	 28 	
3.2	 INTERNATIONAL 	EXPERIENCES OF 	ENVIRONMENTAL 	RISK 	GOVERNANCE	 ................................	....	 29 	
3.3	 INTERNATIONAL 	EXPERIENCES OF 	ENVIRONMENTAL 	RISK 	GOALS AND 	STRATEGY	 ......................	 32 	
3.4	 INTERNATIONAL 	EXPE	RIENCES OF 	ENVIRONMENTAL 	RISK 	ENABLING 	MEASURES	 .......................	 34 	
3.5	 INTERNATIONAL 	EXPERIENCES OF 	ENVIRONMENTAL 	RISK 	COMMUNICATION AND 	ENGAGEME	NT	 37 	
CHAPTER 4. POLICY RE	COMMENDATIONS TO EST	ABLISH 	AN 	ENVIRONM	EN	TAL 	
RISK MANAGEMENT SYST	EM IN CHINA	 ................................	................................	..................	 40 	
4.1	 ESTABLISH	 THE	 RISK	-BASED	 ENVIRONMENTAL	 GOVERNANCE	 SYSTEM	 ................	 41 	
4.1.1 Establish a High	-level, Permanent National Environmental Risk Board	 .............................	 41 	
4.1.2 Establish 	a Comprehensive Environmental Risk	-based Decision	-making System	 ................	 42 	
4.1.3	 Rearrange E	nvironmental Risk	-based Institution	s ................................	...............................	 43 	
4.2	 ESTABLISH	 ENVIRONMENTAL	 RISK	 MANAGEMENT	 GOALS	 AND	 STRATEGY	 .........	 44 	
4.2.1 Set Environmental Risk Management Target	s ................................	................................	......	 44 	
4.2.2 Establish and Implement a Comprehensive National Environmental Risk Management 
Strategy	 ................................	................................	................................	................................	..........	 44

xiii	 	
4.3	 ESTABLISH	 AND	 IMPROVE	 THE	 SYSTEM	 OF	 ENABLING	 MEASURES	 FOR	 	
ENVIRONMENTAL	 MANAGEMENT	 ................................	................................	............................	 46 	
4.3.1 	Strengthen and Complete	 Legislation and 	Strengthen the J	udiciary for 	Environmental 	Risk 	
Management	 ................................	................................	................................	................................	.. 46 	
4.3.2 Enable 	Environmental 	Risk 	Information 	Integration and 	Sharing	 ................................	.......	 47 	
4.3.3 Apply 	Financial	 and Economic	 Instruments to 	Prevent 	and Manage E	nvironmental 	Risks	 . 47 	
4.3.4 Establish a collaborative multi	-department environmental emergency r	esponse system with 	
practical emergency response plan	s as 	a core requirement	 ................................	..........................	 48 	
4.3.5 Establish 	a R	esponsib	ility	 System for 	Indust	ries and 	Enterprises	 ................................	........	 48 	
4.4	 ESTABLISH	 AN	 ENVIRONMENTAL	 RISK	 COMMUNICATION	 AND	 ENGAGEMENT	 	
SYSTEM	 ................................	................................	................................	................................	............	 49 	
4.4.1 Develop a transparent and effective environmental risk communication system	 .................	 49 	
4.4.2 Establish 	Effective E	nvironmental 	Risk 	Engagement 	Programs	 ................................	..........	 50 	
ANNEX	 ................................	................................	................................	................................	..................	 51 	
ANNEX	 1. DESCRIPTION OF 	THREE 	CATEGORIES OF 	ENVIRONMENTAL 	RISKS	 ................................	.. 52 	
ANNEX	 2. PROBLEMS OF 	CURRENT 	ENVIRONMENTAL 	EMERGENCY 	RESPONSES	 ..............................	 53 	
ANNEX	 3. CURRENT 	ENVIRONMENTAL 	RISK 	LEVELS IN 	CHINA	 ................................	........................	 54 	
ANNEX	 4. PROSPECTS FOR 	DRIVING 	FORCES OF 	ENVIRONMENTAL 	RISKS IN 	CHINA	 .........................	 56 	
4.1 Driving Forces of Environmental Risk	 ................................	................................	....................	 56 	
4.2 Prospects 	for	 Driving Forces of Environmental Risk Levels and Public Risk Perceptions	 .....	 58 	
ANNEX	 5. THE 	RISK 	GOALS UNDER 	VARIOUS 	LAWS AND 	REGULATIONS IN THE 	UNITED 	STATES AND 	
THE 	EUROPEAN 	UNION	 ................................	................................	................................	.......................	 62

1 	
CHAPTER 1. 	CU	RRENT STATUS AND FUTURE 	PROSPECTS 	OF 	
ENVIRONMENTAL RISKS IN CHINA	 	
 
1.1 Definition of Environmental Risk	 	
1.1.1 	Concept of E	nvironmental 	Risk	 	
Environmental	 risk 	refers to the 	combination of the 	probab	ility and 	consequence of 	
adverse environmental outcomes from 	an event or activity	 which 	is induced by 	natural 	
cause	s or human activities	. It is determined by assessment of the probability of the eve	nt 	
or activity 	occurring	, the exposure of 	environmental 	receptors	 to the sources of risk	, 	
and the severity of the consequence or loss	. It 	can be 	expressed as:	 	
Environmental risk	 = extent of l	osses due to the 	event/activity	 ×	 probabilit	y of 	it 	
occurring	 	
According to this definition, 	an event or activity can be 	defined as 	an 	environmental 	
risk if it has a probability to 	cause 	environmental 	damage, no matter 	what 	the causes of 	
the event or activity	 (natural or human)	. The losses include not only physical 	effects 	
but also their social valuation.	 	
1.1.2	 Environmental 	Risk 	System and 	Environmental 	Risk 	Chain	 	
In the	 reality of	 environmental risk management, the concept of environmental risk is 	
often 	more in line with the common 	cognitions	 of stakeholders and 	with 	environmental 	
risk management practices	 than 	the 	above 	formula	. The e	nvironmental risk system	 is a	 	
complex	 entity	 which comprises environmental risk sources, environmental risk 	
receptors, and control mechanisms (Figure 1	-1).	 	
 	
Figure 1	-1. 	Environmental risk system	 	
Environmental risk sources	: the source	s of possible environmental hazards	 include	 the	 	
pre	cursors	 of environmental risk events or activities. 	Risk sources can be the 	production	, 	
transport	ation	, utilization	, and storage 	of fla	mmable and explosive materials 	or toxic

2 	
chemicals 	and hazardous materials, 	treatment of 	the 	“three wastes”	 (waste water, waste 	
gas, and solid waste)	, as well as 	long	-existing pollut	ed	 media such as 	emissions yielding 	
chronic air pollution and 	soil	 and 	groundwater	 pollution	 at 	contaminated sites.	 Note that 	
safety accidents 	inside industrial facilities,	 such as chemical explosions	, may	 not 	
automatically	 pose	 hazards to the 	external 	environment	 outside the facility	, but	 the 	
probabilities 	for environmental 	impacts 	do exist	. 	
Environmental risk	 receptors: 	Entities 	such as humans	, ecosystems,	 and socioeconomic 	
structures 	that will suffer from	 risk consequences.	 	
Environmental risk	 control mechanisms: 	Policies, measures, technologies and practices 	
to reduce environmental risks. 	These include e	nvironmental 	risk source control	s at 	
industrial 	facilities	, management mechanism	s and practices	 at facilities, 	and 	the 	
management of	 transport	 networks	. Con	trol mechanisms 	can be classed as 	primary 	or 	
secondary. 	Primary mechanism	s refer	 to 	control system	s to avoid risk factors	 (such as 	
energy and 	pollutants	) being released 	from risk sources. The failure of primary control 	
mechanism	s includ	es the release of energy and pollutants in connection 	with 	natural 	
disasters	, and 	mechanical 	and 	human	 failures	. Secondary 	control 	mechanism	s refer	 to 	
the system	s for	 controlling 	the 	transport	 of released risk factors	 (e.g., blocking and 	
reducing pollutants 	to avoid them	 entering 	into environmental media)	, and 	measures 	
for 	reducing the exposure posed to 	receptors	 (e.g., 	evacuation	 of potentially	 exposed 	
people	). For environmental risks induced by natural disasters, 	secondary control 	
mechanism	s are	 more important for alleviating environmental damage.	 	
Environmental	 risk event	s or activities	 can 	involve all components of 	the 	environmental 	
risk system and 	they 	comprise the 	basic	 processes	 that 	constitute 	the environmental risk 	
chain (Figure 1	-2).	 	
 	
Figure 1	-2. Environmental risk chain	 	
In the whole process from social needs to risk damage, 	causes of environmental risks 	
and their hazards 	may exist in any node of the risk chain. 	The purpose of environmental 	
risk management 	is, first of all,	 to reduce the probabilities of environmental risk	 events 	
happening. The purpose is also to 	reduce the damage if a risk event 	does 	happen	 at 	any 	
node of 	the 	environmental risk chain	. Damage can be minimized 	through laws, 	
regulations, policy, and technical measures	. These steps help 	reduce	 the environmental 	
risks 	facing society	 and 	help 	secure regional	 and	 human health, environmental 	quality	, 	
and 	the functioning and integrity of 	ecosystems	. 	
1.1.3 Determination	 of Categories and 	Scope	 of 	Environmental 	Risks	 	
Based on 	the 	environmental risk	 chain	, the characteristics of the	 process	 from 	
environmental 	risk 	sources 	to damage are different for different types of risks.	 Since

3 	
there is no unified risk classification system in China, for the purposes of this report 
three categories of environmenta	l risk have been defined	 along the spectrum from 	
chronic to acute consequences	 (Figure 1	-3): 	
Detailed description	s of three categories of environmental risks are shown in Annex 1.	 	
 	
Figure 1	-3. Categories of environmental risks	 	
 
1.2 Current 	Status of 	Environmental 	Risks in China	 	
1.2.1 Spati	al and T	emporal	 Characteristics of Environmental 	Risks in China	 	
Accidental environmental pollution incidents.	 	
A recent study	2 analy	sed 	accidental	 environmental incidents 	occurring 	during 	1993	-	
2014 	on the basis of 	data 	provided 	in the	 China 	Environmental Statistical Yearbook	, 	
and as well	 collected 1065 detailed case studies 	during 	2000	-2010 through 	the 	Safety 	
and Environmen	t Journal	, and from 	internet and 	media	 report	s. These records include 	
the first two 	categorie	s of risk	: accidental 	environmental 	events and activitie	s where a 	
threshold is reached.	 Since 	the data do not distinguish between 	Categor	ies	 1 and 2	, we 	
analysed 	the spatiotemporal characteristics of 	all these 	incidents	 considered together	. 	
As for Category 	3 risks	, this study 	provides	 analys	is based on existing	 results	 from other 	
research	es. 	
The 	frequency of 	environmental pollution incidents	 has fluctuated 	with 	a declin	ing	 	
trend (Figure 1	-4). This	 is attributable to 	improvements in	 environmental risk 	
 	 	 	
2 Bi, J et	. al., 2012. R	esearch report of China’s 863 project of “Research on Integrated Technology 	
System of Major Environmental Pollution Accident Emergency Response”, with data updated to 2014. 
Unpublished.

4 	
management driven by environmental risk events	. Environmental pollution incidents 	
happened often 	during the 	early 1990s	, with 	2500	 to 	3000	 cases	. From 1994 to 2000	 	
they fluctuated 	at 	high levels 	and 	then 	decreased and	, after 2005,	 stabilized 	at 	around 	
500 	per year. Little decrease has occurred in recent years.	 	
Serious environmental accidents continue to happen, 	however, 	such as the Dalian oil 	
pipeline explosion in 201	0 and 	the 	Tianjin 	explosion in 2015	. These show that 	
accidental 	pollution event risks in C	hina are still 	prominent	. Although m	issing reports 	
and 	conceal	ment of pollution incidents 	produce 	some uncertainties in the data, the 	
figures 	still reflect the overall trend of environmental pollution incident risks in China.	 
 	
Figure 	1-4 Environmental Pollution Incidents 	in China (1993	-2014)	 3 	
Figure 1	-5 shows the	 spatial 	distribution	 of the 	frequency of 	pollution incidents and 	
the main risk sources	. The graphic draws upon 	environmental 	classification	 results 	from	 	
approximately 46	,000	 	enterprises in 	petrochemical	s, chemical products	, 	and 	
pharmaceutical industries in the 	Inspection of Environmental Risks and Chemicals in 	
Key Sectors and Enterprises	 conducted by MEP in 2009	, and 	from 	the provincial 	
pollution incident data 	in 	China 	Environmental Statistical Yearbook	. 	
Unsurprisingly, the spatial distribution of e	nvironmental accident	s is 	broadly 	consistent 	
with the spatial distribution of major risk sources.	 Figure 1	-5 shows that	 various types 	
of pollution incidents happen where there	 are major risk sources	. T	he areas with dense 	
risk sources have more frequent pollution incidents, especially in eastern coastal regions 
and Hunan and Sichuan	. A	reas with 	fewer 	risk sources have 	fewer 	incidents, such as 	
the 	northwest and northeast regions. Guangxi province has 	fewer 	major risk sources 	but 	
it has 	a high frequency of incidents, 	an anomaly due 	to low environmental management 	
capacity	 and a 	large	 industrial 	infra	structure	. Other studies of 	spatial 	distribution of	 	
accidents reach broadly similar conclusions	4, 5. 	
 	 	 	
3 Statistics	 on extra serious, serious, relatively serious, and ordinary pollution events in 	the	 China 	
Environmental Statistical Yearbook	. 	
4 Zhang, He	-Da and Xiao	-Ping Zheng, 2012. Characteristics of hazardous chemical accidents in China: 	
A statistical investigation. 	Journal of Loss Prevention in the Process Industries	, 25, 686	-693.	 	
5 Li, Yang, Hua Ping, Zhi	-Hong Ma, and Li	-Gang Pan, 2014. Statistical analysis of sudden chemical 	
leakage accidents reported in China between 2006 and 2011. 	Environ Sci Pollut Res	 21, 5547	-5553.

5 	
 	
Figure 1	-5 Distribution of 	accidental 	pollution 	incidents (1993	-2014)	 6 	
 	
Figure 	1-6. Sectoral Distribution of Main Incidents	 7 	
 	 	 	
6 Based on 	analysis of 	provincial statistical data of pollut	ion	 events from 	China Environmental Statistical 	
Yearbook 	and 	data from 	Inspection of Environmental Risks and Chemicals in Key Sectors and 	
Enterprises	 conducted by MEP in 2009.	 	
7 Bi, J et	. al., 2012. R	esearch report of China’s 863 	project of	 “Research on Integrated Technology 	
System of 	Major 	Environmental Pollution Accident Emergency Response”. Unpublished	.

6 	
This study also 	analysed 	sectoral risk sources	 (Figure 1	-6) based on 	a survey of 	1065 	
environmental pollution cases during 2000	-2010	. The results are broadly consistent 	
with the 	literature	 cited above	. Clearly, 	serious	 sector 	structural 	environmental 	risks	 	
exist 	in China	. The order of the twelve sectors with most pollution incidents in China 	
is: chemical raw material and products, water production and supply, road 
transportation, waterway transportation, paper making and paper products, ferrous/non	-	
ferrous metal mining, ferr	ous/non	-ferrous metal smelting/processing, petroleum 	
processing/coking/nuclear fuel processing, power/heat generation and supply, 
agricultural products/food processing, textile 	manufacture	 and petroleum/natural gas 	
exploration.	 	
The study also looked at a	ccidental 	environmental 	risks 	that are 	due to 	industrial 	
layout	. Many chemical production enterprises are located in densely populated areas, 	
either on or near important water sources, 	rivers	, lakes, wetlands	, and ecological 	
protection areas	. These enterpr	ises can 	become major environmental risks.	 	
Results of	 the	 Inspection of Environmental Risks and Chemicals in Key Sectors and 	
Enterprises	, conducted by MEP in 2009	, show that a	mong 46,000 key sector and 	
chemical	 enterprises, 12	.2% are located within 1	 kilometre	 of 	drinking water and 	
ecological function protection areas; 10	.1% are within 1	 kilometre	 of 	densely populated 	
residential areas	; and 72% are along key rivers	 and 	basins such as 	the 	Yangtze, Yellow	, 	
and 	Pearl	 rivers,	 and Taihu Lake	 near Shanghai	. 	
According to the	 Report of Environmental Exposure Related Activity Patterns Research 	
of Chinese Population	 conducted by 	the 	Chinese Academy of Environmental Science	, 	
about 11	0 million people 	live 	within 1	 kilometre	 of 	seven	 major polluting enterprises	, 	
and 	140 million 	live 	within 50 metr	es of main roads	. Th	is report 	also 	examined the 	
main causes for a	ccidental 	environmental 	pollution 	incidents	. 	
A recent 	study	8 of 1605 incidents 	divides the reasons 	for	 primary control mechanism 	
failure 	into	 human facto	rs and external factor	s such as equipment and weather 	
condition	s. Human factor	s are	 the main reason 	for	 incidents	, accounting for 	50%	 to 	
70%	. E	quipment failure such as 	wear	, corrosion, aging	, or extended use	 contribute	s to 	
10	% to 	20%	. P	oor	 institution	al syst	em	s account for about 30%, with a rising trend.	 	
Human factors can be divided into five types	: violation of the 	law, non	-compliance 	of 	
operation, operational error, inadequate management	, and weak capacity. 	Violation 	of 	
the law 	accounts for 38.8% of total i	ncidents	 and is the	 major reason.	 Inadequate 	
management contributes to 36.2%.	 Other 	surveys 	of 	the 	causes of 	China’s 	accidental 	
pollution incidents point to similar causes, although the percentages differ 	among these 	
studies	9. 	
 	 	 	
8 Bi, J et	. al., 2012. R	esearch report of China’s 863 	project of “Research on 	Integrated Technology 	
System of Major Environmental Pollution Ac	cident Emergency Response	”. Unpublished	. 	
9 He, Guizhen; Lei Zhang, Arthur P.J. Mol, Tieyu Wang and Yonglong Lu, 2014. Why small and 
medium chemical companies continue to pose severe environmen	tal risks in rural China. 	
Environmental Pollution	, 185, 158	-167.	 	
Li, Yang, Hua Ping, Zhi	-Hong Ma and	 Li-Gang Pan, 2014. Statistical analysis of sudden chemical 	
leakage accidents reported in China between 2006 and 2011. 	Environ Sci Pollut Res	 21, 5547	-5553.	 	
Zhang, He	-Da and Xiao	-Ping Zheng, 2012. Characteristics of hazardous chemical accidents in 	
China: A statistical investigation. 	Journal of Loss Prevention in the Process Industries	, 25, 686	-693.	 	
Zhang, He	-Da and Wei Liu, 2012. Causes of hazardous chemical accidents in China. 	Journal of 	
Industrial Safety and Environmental Protection	, 11, 10	-11.

7 	
Finally, t	his study 	looked at the 	current status of 	China’s emergency response to 	
environmental incidents	. It 	selected 50 cases from 	Typical Environmental Accidents 	
Cases (Part I)	 (MEP Emergency Response Lead Group Office, 2011)	 to 	analyse 	the 	
main reasons 	for 	the 	ineffectiveness of response	s. The results 	(Annex 2) 	show that 	
China's response capacity is weak	. It 	lack	s effective emergency response plans and 	
scientific support, leading to improper 	response	 measures and poor control 	of 	
environmental 	effects	. 	
Long	-term 	and chronic environmental risks in China	 	
In addition to the above	-mentioned types of environmental risks, there is a third 	type 	
that has existed for a long time in China, but 	has 	been neglected because its effects are 	
not sudden and acute. 	These are 	long	-term	 or 	chronic environmental risk	s, and they 	
include: 	soil contamination risk, health risk 	from 	accumulated air pollution, health and 	
ecological risk 	from 	new emerging pollutants, 	and 	risk from regional development and 	
large	-scale infrastructure deve	lopment on ecosystems.	 	
Soil 	pollution	 	
With 	increasing 	industrialization and urbanization, large 	areas 	of 	China’s 	lands	 are 	
gradually 	becoming contaminated	, bringing significant environmental and health risk	s. 	
The World Bank report 	Current Status of 	Contaminated Site Remediation and 	
Redevelopment	 (2010) indicat	es that land contamination has become an increasingly 	
serious environmental pollution problem in China.	 MEP and 	the 	Ministry of Land and 	
Resources	 conducted the first national soil pollution inv	estigation. The results show 	
that 	the overall condition of soil pollution is 	problematic.	 Over 16.1% of the 	
investigation sites exceed the soil quality standard. 	The degraded s	oil quality of 	
cultivated land	 is 	worrying.	 Soil pollution problems in 	abandoned 	industrial and mining 	
lands are prominent.	 	
Soil quality is influenced by 	many 	factors	. Soil pollution 	in China 	result	s from the 	long	-	
term accumulation of economic and social development	 pressures	. Industrial, mining, 	
and agricultural activities a	nd 	high natural background values are the major reasons for 	
soil pollution in China. 	The	 pollution of c	ultivated	 soil can p	ose serious threat	s to 	
agricultural product	 safety	. 	The r	edevelopment	 of i	ndustrial 	and mining 	legacy 	
contaminated sites 	may pose 	long	-term and chronic health risks to	 the	 public	, especially 	
where there are 	heavy meta	ls and	 persistent organic pollutants 	(POPs	) present	. For 	
example, 	analysis of soil heavy	-metal health risks from 62 	mining areas in 19 provinces	 	10 shows that 	most of the areas have 	a carcinogenic risk	11 of 	between 1×10	-4 and 1×10	-	
5, with 	a certain proportion of mining areas hav	ing	 a carcinogenic risk over 1×10	-4. 	
Clearly, 	heavy	-metal contamination in mining areas 	pose	s fairly high carcinogenic	 as 	
well as 	non	-carcinogenic 	risks 	to human health.	 	
Although 	some practices in 	polluted 	soil 	management and	 remediation	 have been 	
introduced, o	verall	 the number of contaminated sites 	remains 	unclear	, and development 	
 	 	 	
10	 Li, Z., Ma, Z., van der Kuijp, T. J., Yuan, Z., & Huang, L. (2014). A review of soil heavy metal 	
pollut	ion from mines in China: pollution and health risk assessment.	 Science of the t	otal environment	, 	
468	, 843	-853.	 	
11	 Based on risk assessment methodology defined in the 	Technical Guidelines for Risk Assessment for 	
Contaminated Sites	 (HJ25.3	-2014, MEP). The acceptable level for 	carcinogenic	 risk of a single 	
pollutant is defined 	1×10	-6..

8 	
of r	elevant laws and regulations still lag	s. A soil 	risk management system	 adapt	ed	 to 	
the 	China	’s situation	 has not 	yet 	been 	put in place	. 	
Air pollution	 	
In recent years, 	fine particulate matter	 (PM	2.5	) air	 pollution has become a prominent 	
environmental issue in China.	 Numerous epidemiological studies 	around	 the world 	
have demonstrated 	that 	PM	2.5	 is associated with 	negative health effects.	 The 	2010 	study 	
by	 the 	Global Burden of Disease	 (GBD	) showed that 	outdoor exposure to 	PM	2.5	 was 	
the fourth 	most serious 	mortality 	factor in China	 and was	 associated with	 1.23 million	 	
deaths 	per year	. The study calculated	 an average annual 	risk 	of dying 	from this cause 	
when living in 	China 	of 	approximate	ly 10	-3 (Figure 1	-7). 	
 	
Figure 	1-7 Distribution of premature death risks of China from Global Burden 	
of Disease study 2010 	12 	
 
Similarly, Lelieveld et al. (2015) estimated 1.36 million deaths per year in China in the 
year 2010 due to outdoor exposure to PM	2.5	 and ozone.	13 Rohde and Muller (201	5), 	
using new monitoring data from China’s several hundred ground	-level air reporting 	
stations (showing PM	2.5	 levels in China around 50 	μg/m	3 or higher, above the ambient 	
regulatory limits set	 in China at 35 	μg/m	3, in the E	uropean 	Union (EU)	 at 25 μg/m	3 	
and in the US at 12 μg/m	3), estimate that there were 1.6 million deaths per year in China 	
 	 	 	
12	 Yang G, Wang Y, Zeng Y, Gao GF, Liang X, Zhou M, et al. 	(2013). 	Rapid health transition in 	
China, 1990	–2010: findings from the Global Burden of Dise	ase Study 2010. 	The Lancet	 381:1987	-	
2015.	 	
13	 Lelieveld	, J.,	 J. S. Evans, M. Fnais, D. Giannadaki & A. Pozzer	 (2015). 	The contribution of outdoor 	
air pollution sources to	 premature mortality on a global scale	. Nature	 525: 367	-371 (17 September	 	
2015).

9 	
in the year 2014 	due to PM	2.5	 or more than 4,000 deaths per day.	14 In addition to	 these 	
heavy health burdens 	caused by	 outdoor air pollution, almost as many lives are lost in 	
China due to indoor air pollution, primarily from burning solid fuels for cooking and 
heating (Figure 1	-7).	 	
The long	-term health harm of PM pollution cannot be ignored any more. 	The 	public has 	
gradua	lly recognized the health risk of PM	2.5	 along with 	a more general 	increase 	in 	
environment	al awareness.	 As a result, 	China	’s new 	Ambient Air Quality Standards 	
(GB3095	-2012) 	included 	PM	2.5 and 	marked a shift 	in the	 environmental management 	
model from 	an orie	ntation on 	pollution control	 toward an orientation on improving 	
environmental quality. 	 	
Currently, 	the public	 has high	 concern 	about	 PM	2.5	. Meanwhile 	there is insufficient 	
concern about other pollutants	 that also bring health and ecological risks and that will 	
gradually become a bigger problem. These include 	short	-lived climate pollutants	 or 	
SLCPs	 (that is,	 black carbon	 and 	tropospheric	 ozone	) as well as carbon dioxide and 	
methane emissions acting as gre	enhouse gases	. 	
Water pollution	 	
The situation of water pollution in China is serious. According to the 	Environmental 	
Quality Bulletin	 released	 by MEP	, the proportion of 	water inferior to class V (‘	inferior 	
V water	’) 15 is 9.2%	 for 	state	-controlled 	monitoring	 sections in seven river systems	 in 	
2014	. Inferior V water sections 	are 	mainly locate	d in 	the 	Haihe, Yellow, Yangtze, Pearl, 	
and Huaihe 	river	s. In 2013, 	the Chinese Center for Disease Control and Prevention 	
(C	CDC	) issued a report 	titled 	Water Environment and Gastrointestinal Cancer Death 	
Atlas in Huaihe River Basin	, which shows c	onsistency between heav	ily	 pollut	ed waters	 	
and high gastrointestinal cancer rates in 	the 	Huai	he	 River Basin	. The long	-term 	
environmental health risk due to water 	pollution cannot be neglected.	 	
New chemicals and e	merging pollutants	 	
Emerging 	pollutants are chemical pollutants that are newly identified or 	were 	not 	
confirmed in the past	 ─ and	 therefore 	are 	not listed in relevant regulations	 ─ and that 	
pose 	risks 	to 	human health and 	the 	environment. These pollutants are normally 	
generated from human activities, and will not easily decompose in 	the 	environment. 	
Many newly introduced 	materials and chemicals	 have shown obvious health hazard	s 	
and 	an 	environmental presence	, for example,	 nanomaterial pollution, f	luorinated 	
organic compounds	, e	nvironmental endocrine disruptors	, antibiotics, 	and 	flame 	
retardants. 	In 	recent years, more studies 	show 	that emerging pollutants have been 	
detected in environmental media at many place	s in China	, and 	so 	the risk of 	these 	
pollutants to 	the 	environment and human health 	deserves attention	. 	
 	 	 	
14	 Robert A. Rohde and Richard A. Muller (2015)	. Air Pollution in China: Mapping of Concentrations 	
and Sources	. Univ. of California at Berkeley, 	http://berkeleyearth.org/wp	-	
content/uploads/2015/08/China	-Air	-Quality	-Paper	-July	-2015.pdf	 . 	
15	 China	’s Environmenta	l Quality Standards for Surface Water (GB3838	-2002)	. Surface water quality 	
is classified into five classes with different functions. Class I is the highest 	quality 	and applicable for 	
river sources and nature reserves, while Class V is the lowest and applic	able 	for general agriculture and 	
landscape use. 	http://kjs.mep.gov.cn/hjbhbz/bzwb/shjbh/shjzlbz/200206/t20020601_66497.htm

10 	
Taking antibiotic	s as an example, research 	conducted 	in Jiangsu and Zhejiang 	by Fudan 	
University 	on exposure of children to multiple antibiotics show	s that among 1000 	
children tested, at least 58% were 	detected with one type of antibiotic in urine samples 	
and 25% were detected with two types of antibiotics	 16. Furthe	rmore	, the 	Ten Years 	
Investigation Report of Antibiotics in China	 issued by CAS Guangzhou	 Geochemistry 	
Institute in 2015 concluded that 	the 	resistance of bacteria to antibiotics 	can be partly 	
attribute	d to 	antibiotics found in the 	environment.	 	
Thus	, the 	environmental and health risks of emerging pollutants 	need to	 be addressed 	
in environmental risk management to avoid a 	repetition of the 	way 	that	 pollution from 	
heavy metal	s, organochlorine pesticides, and PCBs	 has	 become a major environmental 	
risk	. 	
Solid waste	 	
Along with 	rapid 	industrialization and 	urbanization, en	vironmental pollution due to 	
industrial solid waste	 (especially hazardous waste)	 and m	unicipal 	solid 	waste	 are 	
becoming more prominent.	 For example, i	t is estimated that	 up to 5 million square 	
meters of soil have been contaminated by 	chromium slag	17. Improper disposal of solid 	
waste risk	s damage to environmental quality and 	to 	ecosystem and human health.	 Solid 	
waste issues may cause social conflict, such as the public protest events against w	aste 	
incineration project	s in recent years. E	nvironmental risk	s of s	olid waste 	warrant review.	 	
Ecological 	impact of	 regional development	 	
With 	rapid 	industrialization and urbanization, 	China’s 	long	-term and chronic 	ecosystem 	
change	s caused by regional development 	are 	a part of the environmental risk 	
management 	challen	ge.	 The 	Ecological Footprint 	Report 	of China 2012	 indicate	s that 	
since the 1970s the consumption of renewable resources in China has exceeded 	their 	
capacity to regenerate	. Ecosystems fac	e ever increasing pressure from population and 	
development. The long period of overdevelopment has resulted in serious degradation 
of ecosystems. Regional development has led to 	the 	continuous decrease of natural 	
ecosystems such as forest, bush, grassland	, and wetland, as well as 	the 	decrease of 	
natural habitat quality and biodiversity. 	 	
Ecological risks brought 	on 	by regional development have major implications on 	
national ecological security.	 In 2015	, the State Council issued the 	Vision and Actions 	
on Join	tly Building Silk Road Economic Belt and 21st	-Century Maritime Silk Road	, 	
signalling 	that the “Belt and Road” is in the process of moving from 	concept	 to 	reality	. 	
The 	Silk Road Economic Belt	 will pass though 	sensitive ecosystem	s in Western China. 	
Large	-scale infrastructure construction and regional development	 may pose further 	
threats to regional ecosystems.	 	
Radiation sources and 	nuclear wastes	 	
Radiation sources have been widely used in different sectors including 	medical and 	
health care, scientifi	c research, 	and 	industrial production	. Radiation source	s may	 affect	 	
the environment and public	 health 	if there is 	improper management. 	The r	adiation 	
 	 	 	
16	 http://www.chinadaily.com.cn/hqgj/jryw/2015	-04	-13/content_13536869.html	 	
17	 From the 	12th Five	-year Plan for Hazardous Solid Waste 	Polluti	on Control of China	.

11 	
source	s census	 conducted by 	the 	former 	Environmental Protection Administration, 	
Ministry of Health, and 	the 	Ministry of 	Public 	Security	 in 2004 shows that 	there were 	
more than 10 thousand units with 	more than 140 thousand 	radiation sources in China. 	
Radiation source accidents have occurred in recent years, including the radiation source 
lost incident	 in Nanj	ing in 2014	18. Clearly	, China's radiation source management level	s 	
need to be improved.	 	
Meanwhile, 	China's nuclear power industry is developing rapidly	. As of March 2015	 	
23 	nuclear power unit	s were operating while 26 were under 	construction. 	Furthermore, 	
45 units 	are “	under preparation	” and 177 	are 	planned	19. With more use of nuclear power 	
in China, the environmental risk	s of nuclear waste disposal will become a prominent 	
issue. T	he inherent hazards of used nuclear fuel are primarily its radiotoxicity	 and its 	
chemical toxicity. 	Due to radioactivity and cumulative characteristics, 	the 	long	-term 	
presence of 	even 	small amount	s of radiation sources and nuclear wastes may cause 	
long	-term and cumulative health damage	 to humans and the environment. 	 	
1.2.2 Current Situation of Public Perceptions	 of Environmental Risks in China	 	
Al	though the frequency of environmental pollution incidents has 	shown 	a decreasing 	
trend 	since the 1990s, 	the level	 that the public is likely to regard as acceptable or 	
tolerable	 is 	also 	decreasing	. This leads 	to 	a new characteristic of environmental risk in 	
China	: increasing 	public	 demand for 	environmental 	protection 	(Figure 1	-8). 	 	
This 	demand 	is seen with the increase in environment	-related mass protests every year	. 	
The adverse 	effe	cts 	of numerous pollution incidents have resulted in 	growing 	
resentment, panic	, and 	public 	resistance to industries 	posing	 potential risks, and the “not 	
in my backyard” effect	. Mounting 	public demands and their dissemination through 	
various media are havin	g more influence on infrastructure construction projects and 	
policy development, such as the many protests against the PX 	(para	-xylene) 	chemical 	
and 	waste incineration	 projects which have occurred in recent years	20. Environmen	tal 	
complaint	s and demands 	ha	ve	 become one of the main 	challenges 	in 	China’s 	
soci	oeconomic	 development	. 	
Therefore, environmental risk management cannot be isolated from 	the 	public’s 	
perceptions of 	risk and acceptable risk level	s. On the one hand, as long as 	actual 	
environmental risk lev	els are	 higher than 	what the public will tolerate	, conflict will be 	
inevitable. On the other hand, 	the large 	gap between 	actual 	risk level	s and 	the 	public’s 	
risk perception	 may be caused by lack of knowledge	, not 	by 	policy 	choice	. Information 	
dissemination through news media may result in 	amplification or 	exaggeration of risk 	
information	, which may magnify 	perceptions beyond 	the actual risks,	 especially 	
regarding sudden highly visible incidents. 	 	
At the same time,	 there are also m	any instances of the public being unaware of the risk	s 	
surrounding them, 	especially chronic long	-term exposures. 	The 	public	’s 	
 	 	 	
18	 http://news.xinhuanet.com/politics/2014	-05/11/c_126484963.htm	 	
19	 Park Duri (PIAO, Douli), Study on China’s nuclear power development in coastal regions and	 	
environmental issues	, undergraduate thesis of Peking University, 2015. 	Park Duri obtained these data 	
from World Nuclear Association	, Medium and Long	-term Development Plan for Nuclear Power 	
(2005	-2020)	, and 	Action Plan of Energy Development Strategy (2014	-2020)	. 	
20	 http://www.mzyfz.com/cms/minzhuyufazhizazhi/jujiaoyuzhuanti/html/696/2012	-11	-30/content	- 	
591810.html

12 	
misunderstanding 	about actual	 risk	 level	s (either overstating or understating 	them	) 	
could make it 	difficult	 to achieve the objective	s of risk management. 	 	
One should keep in mind that public risk perception is not uniform: there is a wide 
distribution of preferred risk levels that individuals find acceptable or tolerable. Public 
estimates of acceptable risk lev	els are also not uniform among risk sources. 	Data about 	
public perception	s are important to understand public concern and to design better 	
communication	s about risks	 and more socially acceptable 	risk 	management strategies. 	 	
 	
 	
Figure 	1-8. National 	Environmental Complaints Letters	21 (Note: Environmental 	
complaints though internet and telephones were counted separately. Data after 	
2011 include complaints from letters, internet, and telephones.)	 	
 
1.2.3	 Current Environmental Risk Levels in China	 	
According to 	the 	above analysis, 	types of e	nvironmental risk	 are	 complicated and 	so 	it 	
is 	inappropriate to use a single indicator to characterize environmental 	risk level	s. 	For 	
this study	, seven 	representative indicators from 	seven 	environmental risks 	were	 selected 	
to characterize c	urrent 	environmental 	risk 	levels in China	: accidental pollution events	, 	
 	 	 	
21	 Data from	 China Environmental Yearbook	.

13 	
soil, air, and water pollution	, climate change	, economic loss	, and public 	complaints	. 	
Together, these indicators can form 	an 	“environmental risk rose	” (Figure 1	-9). 	
Overall, environmental risk levels in China 	remain 	high.	 Note that this figure 	presents 	
the result of only a	 preliminary 	and semi	-quantitative 	analysis	 and that the distances 	
between circles are not to scale 	─	 the points around a given circ	le do not necessarily 	
represent equal levels of risk or seriousness	. Specific and systematic environmental risk 	
assessment is needed in China to add more indicators to complete the risk rose and 
obtain	 more accurate risk level 	assessments	. Detailed descriptions of 	the 	environmental 	
risk rose are shown in Annex 3.	 	
 	
Figure 	1-9. Environmental risk rose of China (	Based on 	Annex Table 3	-1; the 	
blue solid 	line represents current risk levels	) 	
 	
1.3 	Prospects 	for 	Environmental Risks in China	 	
1.3.	1 Overall Prospects 	for	 Environmental Risk Levels in China	 	
Based on the 	analyses 	of p	rospects for 	driving 	forces of 	environmental 	risk	 levels and 	
public 	risk 	perceptions	 (Annex 4	), this study puts forward	 three 	management scenarios 	
to 	discuss the future 	prospects 	for 	environmental risk levels.	 	
Scenario 1:	 Environmental management 	will 	be 	maintain	ed	 in 	the 	current 	mode	, that 	
is, event	-driven	, focus	ed	 on environmental quality	 without systematic risk management 	
(Business as Usual s	cenario).

14 	
Scenario 	2: A systematic 	environmental 	risk 	management	 system 	is established	. 	
For Scenario 1	 and 	Scenario 2	, the study does not 	consider the effects of environmental 	
risk communication	 and engagement	. 	
Scenario 	3：	Based on 	Scenario 	2, the effects of environmental risk 	communication	 	
and engagement	 are 	also 	incorporated.	 	
Figure 1	-10 shows the historical and future 	prospects 	for 	environmental risk levels and 	
public environmental risk acceptance levels.	 It should be noted that the lines are 	
illustrative.	 Levels of actual risks, and of public acceptance of risk, are more complex 	
and multifaceted than can be depicted in 	simple 	lines. 	The scientific basis for 	claiming 	
that environmental risk was much higher in the past	 is based on the 	historical trend of 	
acci	dental pollution events, but there is a lack of 	information	 about	 other risks	, 	
particularly long	-term chronic risks	. 	
The ability of a new risk	-based environmental management system to reduce overall 	
risk is anticipated, but the line shown here (Scenario 2	) is 	a qualitative and intuitive	 	
perspective	 and is not based on a forecasting model. 	Is it clear 	in some cases 	that the 	
public risk acceptance level will be higher following risk communication and	 	
engagement	 (Scenario 3	, blue area with black board	er) than the case	s without 	
communication (	grey line)	, because c	ommunication and engagement will 	reduce	 	
rumours and fears	. In 	other 	cases communication and engagement may	 increase the 	
awareness level of previously neglected risks and hence decrease the acceptance leve	l. 	
The overall trend of risk acceptance level is expected to 	decrease	, with 	early 	
involvement of risk communication and engagement	, which 	can reduce 	unnecessa	ry 	
public 	concerns.	 	
 	
Figure 	1-10	. Prospects	 for	 environmental risk levels and public environmental 	
risk acceptance levels	 in China

15 	
Historical 	trends	: 	
An underlying premise in Figure 1	-10, indicated in the red line for current risks, is that, 	
driven by 	environmental events, environmental risk management	 levels	 have been 	
improving	 in recent years	, that is	, current risks have declined in response to new policies. 	
For example, 	since the Songhua River water pollution accident in 2005, China has 	
implemented a	 series of measures to address sudden pollution accidents.	 After a series 	
of heavy metal pollution incidents, China issued the 	12	th Five	-year Plan of 	
Comprehensive Heavy Metal Pollution Prevention	. The o	verall 	accidental 	
environmental risk level	 has kept decreasing since 	the 	1990s (red line) which is 	
attributed to 	improvement	 in environmental risk management levels. This may depict 	
the trend for acute accident 	events 	(as indicated above in Figure 1	-4), but it may not 	
represent the trend 	for	 long	-term 	chronic 	risks 	which appears to have been increasing 	
through this period (see Section 1.2.1 above). The 	large	 increase in 	risk sources	, for 	
example,	 for 	heavy chemical industrial capacity	 and 	combustion of coal, and a generally 	
higher ecosystem vulnerab	ility may 	thus	 point in the direction of higher risk levels over 	
time. Latent risks from years of chronic air, water	, and soil pollution are beginning to 	
materialise over time.	 	
Meanwhile	, along with increases in national income and education levels, the p	ublic 	
acceptance level	s for 	environmental risk are decreas	ing	 more rapidly than the actual 	
environmental risk level (blue line). In recent years (especially the last 10 years), public 
risk acceptance level	s ha	ve	 been lower than the actual environmental ris	k level	s. T	he 	
gap between them keeps growing, which contributes to continuing s	ocial 	conflicts. 	 	
Future	 prospects	: 	
Figure 1	-10 	offers three possible scenarios. These are 	“educated 	perspectives	” and are 	
not based on data or forecasting models.	 	
Scenario 1	: Driven by economic growth and industrialization (especially the growth of 	
heavy chemical industries	 and coal combustion	), the pressure 	on	 environmental risks 	
will keep growing. 	However, based on historical experience	 ─ where environmental 	
management respon	ses were	 driven by accidents 	or by 	acute environmental risk events	 	
─ the increasing ambition of environmental risk management policies and the progress 	
of environmental protection science and technology will limit 	the 	increase in 	
environmental risk to some	 extent. E	nvironmental risks which have been known for 	
some time will stabilize or decrease slowly	. M	eanwhile, emerging risks will 	complicate 	
the environmental risk situation. The environmental risk prospect in this scenario 
includes uncertainties (	orange 	area).	 Risk levels	, however,	 will not meet public 	
acceptance levels. The gap between them will also keep growing, 	and 	the risk situation 	
will remain problematic.	 	
Scenario 	2: Establishing and 	completing 	the risk	-based	 environmental management 	
system	 will 	comprehensive	ly elevate 	the level of 	ambition of	 environmental risk 	
management in 	China. 	Th	us	, environmental risk level	s will keep decreasing and the gap 	
between 	actual 	risk level	s and public perceptions will 	shrink	. The e	nvironmental risk 	
gap	 could 	be 	significantly 	alleviated	 under this scenario	. 	
Public risk acceptance level	 (without consideration of environmental risk 	
communication and engagemen	t)	：	W	ith soci	oeconom	ic development	, national

16 	
income and 	education levels will keep rising, which will lead to	 a continual decrease in 	
public risk acceptance level	s (grey line	). At the same time, other risks may be 	
underestimated	 or neglected 	by the public	. As the public	 gain	s knowledge about the 	
underestimated or neglected risks, 	however, 	the acceptance levels for these risks 	are 	
expected to	 decreas	e. If there is no risk communication and engagement, the public 	
would probably 	conclude that these risks are too high to be tolerated.	 	
Scenario 3: 	Establishing and implementing a reasonable envi	ronmental risk 	
communication and engagement system, 	along 	with 	the 	expected	 actual 	risk 	reduction 	
achieved by	 Scenario 2	, will help change the risk perception levels in line with 	
soci	oeconomic development levels (	that is, 	bringing	 the 	grey line	 up	 to 	the 	blue	 area	). 	
This 	will lead the 	actual 	environmental risk levels to meet the increasing public 	
demands on environmental safety. 	At the same time, risk communication may increase 	
awareness of some previously neglected risks. This resolution of the gap between	 actual 	
risk levels and public preferences could be a major	 overall goal of environmental risk 	
management in China. However	, it is hard to determine when China will achieve this 	
goal.	 The goal should take account of the benefits and costs of actual policy 	options to 	
reduce risks.	 	
1.3.	2 A Preliminary Scan of Environmental Risks in the Short and 	Medium	 Term	 	
Future	 	
Based on the 	analysis of 	the 	current status and future prospects of environmental risks 	
in China, this report 	provides a 	preliminary 	identification of 	environmental risks	 of high 	
concern in the near future for the three categories of risks	 (Figure 1	-11	). 	
During the 	13	th FYP 	period 	and 	beyond,	 China 	should 	continue to take measures to 	
address 	those 	environmental risks 	to 	which attention 	is 	already 	be	ing	 paid 	in 	the 	current 	
stage 	to 	the year 2015 	(for example	, chemicals, 	eutrophication, 	heavy metals, PM	2.5 and 	
so on	). Soon after 2015,	 China 	should 	start pa	ying	 attention to th	os	e risks which 	are 	
overlooked currently (	for exa	mple,	 ozone, black carbon, 	greenhouse gases	, nuclear 	
wastes 	and radiation, 	and so on	) and 	also to 	the risks 	that 	may 	occur	 in the future (	for 	
example,	 ecological risks 	associated 	with the	 Belt and Road 	construction	). Note that 	
this is a preliminary 	analysis	. F	urther in	-depth research and assessment is 	needed 	to 	
identify and prioritize the future environmental risks in China.	 	
Climate change presents an 	ongoing risk. 	In November 2014 	China 	committed to have 	
its 	greenhouse gas (GHG) 	emissions peak by 2030 and decline 	after that. 	Major policy 	
measure	s are being put in place	, including for a national GHG emissions 	cap	-and	-trade 	
program, and	 targets	 to increase 	the	 use of renewable energy sources.	22 	
 	 	 	
22	 http://www.nytimes.com/2015/09/25/world/asia/xi	-jinping	-china	-president	-obama	-summit.html

17 	
 	Note	：SLCPs: Short lived climate pollu	tants; BC: Black carbon; POPs: Persistent organic pollutants.	 	
Figure 	1-11 	Preliminary 	scanning of 	environmental 	risks	 of concern	 in 	the 	short 	
and 	medi	um	 term	 future	 	
 	
1.4 	Principles of Environmental Risk Management	 	
Based on the analysis of 	the 	current status and future prospects 	for	 environmental risks 	
in China, this report	 summarize	s the p	rinciples 	for	 environmental 	risk 	management	 that 	
will	 provide 	a basis 	for policy recommendations. 	 	
(1) 	Cost	-effective	/cost	-beneficial	 	management.	 	Since 	environmental risk 	
management resources are limited, it is important to manage environmental risk	s in a 	
cost	-effective way.	 Cost	-effective management of environmental risk is obtained 	whe	n 	
a given objective is attained at least cost; a cost	-benefit approac	h seeks to optimize 	
objectives	 where 	the	 marginal value or benefit of environmental risk reduction 	action 	
is equal to 	the marginal cost of the action	. Across the elements of environmental risk 	
assessment and management, 	these approaches	 can play a role, for example in t	arget 	
setting based on cost	-benefit analysis, 	modelling to forecast environmental risk 	
outcomes, and the 	valuation 	and selection 	of environmental risk reduction measures	 	
including legal 	and economic 	measures	. 	
(2) Synerg	istic management	 and 	tradeoffs	. Different environmental risks are 	
inter	related, and are related to other risk	s such as 	food safety, 	work	place	 safety risks	 or 	
social	 risks. Reduction of a risk may 	increase or decrease another risk. Thus the 	
synergistic effect	s among risks	, and tradeoffs among them,	 should be considered in 	
environmental risk management	 ─	 with the objective of reducing overall risk.

18 	
(3) 	Differentiated management for different risk types	. Different environmental risk 	
management 	scheme	s and 	measures	 are needed for different risk types, which require 	
the 	clarif	ication of	 the characteristics of different risks based on 	a comprehensive 	
environmental risk analysis and assessment in China. 	 	
(4) Dynamic 	and 	adaptive 	management	 over time	. Environmental risk 	management 	
measures need to be in line with	 the characteristics of the 	particular stage of 	social	 and 	
economic 	development. 	Further, risk management policies need to learn from and 	
respond to changes over time in knowledge, technology, a	nd public values.	 This 	
requires dynamic evaluation and 	adaptation	 through 	monitoring, analysis, and 	the 	
adjustment 	or revision 	of	 environmental risk management 	policies	. 	
(5) 	Differentiated management	 across regions	. Environmental risk management 	
measures need to be in line with the social 	and 	economic characteristics 	of different 	
region	s. This 	requires regional environmental risk analysis and assessment	, and 	
targeted risk management strategies	. 	
(6) Environmental risk	 communication and engagement.	 The development and 	
implementation of any environmental risk management measure 	needs to 	communicate 	
information to the public, and 	as well, 	elicit and 	consider the 	preferences	 of 	the 	public 	
and relevant 	citizens 	groups 	and 	communities	. This requires that	 sufficient	 and effective 	
risk communication and engagement	 be carried out.

19 	
CHAPTER 2.	 CURRENT STATUS AND DEMANDS OF ENVIRONMENTAL 	
RISK MANAGEMENT 	SYSTEM	S IN CHINA	 	
 
2.1 	Urgency of Environmental Risk Management System	 Construction in China	 	
The 18th National Congress of the CPC introduced 	the	 goal 	of 	building a moderately 	
prosperous society 	by	 2020 and incorporat	ing	 ecological civilization into the overall 	
design 	of socialism with Chinese characteristics	 (that is, 	promot	ing economic, political, 	
cultural, social, and ecological progress	). Opinions of the Central Committee of the 	
Communist Party of China and the State Council on Further Promoting the 
Development of Ecological Civili	zation	, issued in 2015, maintains the 	basic state 	
policies of conserving resources and protecting the environment. It puts the 
development of ecological civilization in a prominent strategic	 place	 that is 	
incorporated into the whole process of economic, political, cultural, and social 
developm	ent. In the same year, t	he Central Committee of the Communist Party of China 	
and the State Council	 issued the	 Integrated Reform Plan for Promoting Ecological 	
Civilization System	 to accelerate the establishment of a complete e	cological 	civilization 	
system	 and to promote the construction of e	cological 	civilization	. 	
Now with China at the 	critical 	point 	of completing	 the building of a moderately 	
prosperous society	 and accelerating the 	construction of 	ecological 	civilization	, a serious 	
environmental risk situation and 	gap	s between risk levels and public perceptions 	have 	
become major 	factors 	restraining 	development. 	Further	more	, environmental problems 	
have grown to become a major 	issue 	affect	ing	 national security. 	 	
The 	National Security L	aw of China	, implemented in 	2015	, notes the need 	“to 	
strengthen the early warning, prevention, and control of ecological risk, and to 	address	 	
accidental	 environmental incidents properly	.” Environmental	 safety 	thus is being 	
recognized as part of	 the national security system	. 	
In 	the 	face of increasing 	public 	demands 	for environmental	 protection	 and the needs of 	
national 	security	, it is 	urgent to transform environmental management 	policy into an	 	
environmental risk management 	system 	that 	focuses on risk prevention and 	reduction	 	
and thus support	s the achievement of ecological civilization.	 	
To improve the environmental risk situation	 in China	, to 	eliminate the gap between 	
environmental risk levels and public acceptance levels, and 	to protect	 national security, 	
an effective and efficient environmental risk management system is needed. The release 
of 	Ambient Air Quality Standard	s (GB 3095	-2012)	 showed that environmental policy 	
has begun to 	transition 	from an 	approach focus	ed	 on pollution control	 to a 	more 	
pro	active approach focus	ed	 on	 improving 	environmental quality	. 	
The environmental risk management system	, however,	 remains 	incomplete	. It 	cannot 	
support 	the	 ultimate	 transformation	 to the environmental 	risk 	management mode with 	
the	 objective of risk prevention and reduction	, and 	it cannot meet the 	increasing 	public 	
demands 	for eco	-environmental safety	. 	
To support policy recommendations on an	 environmental	 risk	 management	 system for 	
China, t	his chapter analyses the current status and 	deficiencies	 of 	the 	environmental

20 	
risk management system from four perspectives: environmental risk governance, 	goal	s 	
and strategies, 	enabling measures	, and 	environmental risk communication and 	
engagement	. 	
2.2	 Incomplete 	Environmental 	Risk 	Governance System in China 	 	
During 	the past	 30 years, to address the environmental problems 	accompanying rapid 	
soci	oeconomic development, industrialization, and urbanization, environmental 	
governance has been improving. Howeve	r, during 	the 	past 10 years, frequent 	accidental 	
environmental incidents have attracted more 	public 	attention	 ─ and environmental risk 	
management has attracted the government’s attention.	 	
The Songhua River water pollution accident in 2005 led to improvemen	ts in prevention 	
and emergency response capacity. 	Conditions	 such as elevated	 levels of	 lead in 	
children’	s blood and PM	2.5	 air 	pollution 	pose 	environmental risks due to cumulative 	
pollution levels have attracted more attention from government. 	Environmental risk 	
issues have been gradually incorporated into national decision	- making system	. 	
The 	18th National Congress of 	the 	CPC proposed to incorporate ecological civilization 	
into the overall layout of socialism with Chinese characteristics. Envi	ronmental risk 	
prevention was 	introduced 	into the 	Twelfth Five	-year Plan for National Economic and 	
Social Development	. The 	Opinions on Strengthening Major Environmental Protection 	
Tasks by the State Council	 in 2011 proposed to establish more efficient environmental 	
risk management and emergency response system	s. The 	National Security Law of 	
China	, implemented in 2015	, formally incorporated environmental safety into the 	
national security system and 	notes the 	need 	“to strengthen the early warning, prevention, 	
and control	 of ecological risk, and to 	address accidental environmental incidents 	
properly	.” 	
Overall, 	the 	environmental management system 	in China 	is still 	at 	an 	early stage. 	It is 	
still event	-driven in ma	ny cases	, and still focuses on 	short	-term 	pollution control. A risk	 	
prevention and	 reduction	 environmental management mode has not been formed. From 	
the macro perspective, the environmental governance system 	remains 	incomplete.	 	
 (1)	 A c	omprehensive e	nvironmental 	risk	-based decision making system has not 	
been 	established	 	
At 	the national strategic level	, the 	current environmental management system has not 	
considered sufficiently 	the 	risks posed by 	eco	nomic	 development or regional	 	
development	, or the	 risks due to industrial layout from the perspectives of 	
environmental risk in 	decision	-making	. Environmental risk assessment has not been 	
comprehensively and substantially incorporated into 	major 	national strategies and plans 	
(such as	 the Five	-year Plans	, new	-type urbanization, 	the 	Belt and Road initiative, 	
integrated development of Jing	-Jin	-Ji area, and 	the 	Yangtze River Delta economic zone	). 	
Although environmental risk prevention has been incorporated into the 	Twelfth Five	-	
year Plan for National Econom	ic and Social Development	, environmental risk 	
management is still in a r	elatively weak 	position compared to e	conomic development	. 	
The 12	th FYP 	only requires the prevention of environmental risks during the 	
implementation of the plan	; it does	 not 	require a 	decision on 	whether and how to 	
implement	 the plan based on environmental risk assessment results. 	In any event	,

21 	
consideration of environmental risks in the process of 	developing 	policies and plans is 	
lack	ing	 for 	governments at all levels	. 	
(2) 	A neutral and scientific institution	 to oversee and support environmental risk 	
assessment and management	 is missing	 	
Environmental risk assessment and management are professional tasks 	requiring	 	
objectivity and impartiality	 during 	environmental risk assessme	nt and supervision	. 	
Thus	, government 	should value the 	results produced by	 scien	ce	-based 	environmental 	
risk institution	s that 	provide a neutral and cred	ible source of	 information and risk 	
assessments.	 However	, China 	lack	s a neutral institute to provide 	scientific risk 	
assessment	s for nation	al decision making 	to guide, coordinate, 	and oversee 	
environmental risk management practices	. 	
(3) 	The i	nstitutional structure of environmental departments cannot meet the needs 	
of environmental risk management	 	
The e	nvironmental management system in China 	is vertically and horizontally 	
fragmented	. T	echnically	, local environmental departments receive guidance from 	
higher	-level environmental departments, but administratively they are subject to 	
management from local gov	ernments. 	The routine environmental supervision of local 	
environmental department	s is restricted by local governments, which results in weak 	
enforcement.	 	
Within MEP, 	due to	 the	 lack of 	an integrated, top	-down 	design, various departments 	
have overlapping	 responsibilities	. This 	has 	caused 	difficulties 	in the 	coordinated 	
management of environmental risk	s. For instance, 	the 	departments of Pollution Control, 	
EIA, Laws and Regulations	, and 	the 	Emergency Response Center have 	individually 	
developed their own 	environmental risk assessment methods. Some departments have 	
too broad functions	. For example,	 the	 Department of Pollution Control is known as 	
“mini MEP” 	because it has 	responsibilities in multiple fields including water, air, solid 	
waste, chemical	s, vehic	les	, and oceans. 	 	
According to analysis of risk sources of	 accidental e	nvironmental 	pollution i	ncidents	, 	
the 	production, storage	, and transportation	 of hazardous c	hemicals	 are the major 	
sources of 	these 	accident	s in China.	 The 	2015 h	azardous 	chemical	s warehouse 	
explosion in 	Tianjin	 again shows 	the 	need to strengthen the integrated management of 	
these 	chemicals and environmental risk control. Currently, 	several 	government 	
agencies	, including those responsible for 	safety supervision	, 	public security	, 	
envir	onmental protection, and health	 are involved in	 chemical	s management.	 Within 	
MEP, chemical	s management involves 	departments such as 	Department of Pollution 	
Control and 	the 	Emergency Response Center	. The 	power and responsibilit	ies	 for 	
chemical	s management overall are	 unclear	, which has led to ineffective 	control	 of 	
environmental risks	 of chemicals.	 	
2.3 Lack of 	Environmental 	Risk 	M	anagement 	Goal	s and 	Strateg	ies	 	
According to 	the 	China Environmental Statistic	al Year	book	, the frequency of 	
environmental pollution accidents	 is down to about 500 every year	 after 2005	, which 	
indicates 	some	 effectiveness 	in environmental risk management work.	 However, public	 	
perception 	of	 acceptable risk level	s keeps lowering 	while	 social and economic

22 	
developmen	t level	s 	rise	. Meanwhile, 	long	-term chronic exposures, such as to air 	
pollution, continue at high levels. T	he conflict between acceptable environmental risk 	
level	s for risk control 	and the public	’s acceptable level	s will be become more 	prominent 	
in the 	future.	 	
It is necessary t	herefore	 to control environmental risks within 	levels 	acceptable to the 	
public. 	To achieve 	this 	objective, environmental policy must be changed	 from	 pollution 	
control	 and quality improvement	 approach	es to a more 	pro	active risk prev	ention and 	
reduction approach.	 There is	 still a long way to 	go, however, to 	advance 	the	 risk 	
management	 system	. It 	requires the development of relevant objectives and strategies 	
to facilitate the transformation of the environmental management mode.	 	
A more	 robust overall	 objective is to maximize social well	-being through the 	
management of environmental risks. Public perceptions can be highly varied (no single 
risk acceptance level is possible), so the net benefits of different risk management 
policies and m	easures will depend on the type of risk	 and 	the 	costs of control. 	While 	
public valuations need to be incorporated in	to those benefit estimates	, 	public 	
perceptions can 	sometimes 	misjudge risks, overstating 	or 	understating	 them	. 	
To date, a complete set of en	vironmental risk management goals	, and 	the 	strategies to 	
meet them	, have not been developed in China.	 The 	State	 Ministry of Work Safety issued 	
the 	Personal and Social Acceptable Risk Criteria for Hazardous Chemical Production 	
and Storage Enterprises (trial	) in 2014, which proposes management criteria for new 	
and existing facilities in different types of areas.	 Although 	this	 standard is for	 safety 	
risk 	management of h	azardous chemicals	, it offers a reference for criteria for the 	
management of accident 	environmental risks, since safety 	accidents 	involving	 	
hazardous 	chemicals are closely related to pollution accidents. 	In addition	, the 	
Technical Guideline for Risk Assessment of Contaminated Sites	, released in 2014	, 	
recommends the methodology and sets acce	ptable levels for non	-carcinogenic and 	
carcinogenic risk	s. 	The	se	 recommended criteria	, however,	 mainly 	rely on	 US criteria 	
for reference. Further studies are needed to determine whether	 the	se	 criteria are suitable 	
for China. 	 	
Already t	here have been 	prelim	inary attempt	s to set 	environmental risk management	 	
goals in China	, b	ut 	there are no goals	 in national strategies or laws to support 	the overall 	
goal of 	control	ling	 environmental risk	 levels	 due to soci	oeconomic development at 	
levels acceptable to the 	public	. Environmental risk types are complicated	, and 	
environmental risk levels are different for 	different	 so	cioeconomic development level	s 	
in different 	regions and 	period	s. Further studies are needed to explore environmental 	
risk management goals and cri	teria for different regions, periods, and types of risks.	 	
An environmental risk management strategy and system has not 	yet 	been established in 	
China. The	 current situation 	and 	prospect	s for	 environmental risk	s are	 unclear. There is 	
a lack of a 	comprehensive and integrated national environmental risk assessment and 	
ranking of priority risks	. Furthermore, there is a lack of	 research on the mechanisms 	
through which environmental risks induce other risks	, such as social 	stability	, economic 	
security,	 and national and regional security. 	The 	management 	priorit	ies	 for	 	
environmental risk	s are un	clear	, and cannot support the development of environmental 	
risk management strategies.

23 	
2.4 Insufficient 	Enabling 	M	easures 	System for 	Environmental 	Risk 	M	anagement	 	
In recent 	years	, to meet the needs of environmental risk management in the context of 	
frequent	 environmental pollution event	s, 	environmental protection department	s have 	
been	 constantly improving the enabling measures system for environmental risk 	
manageme	nt. 	Overall, h	owever, the system of enabling measures 	remains 	incomplete, 	
and cannot 	yet 	meet the requirements for effective and comprehensive environmental 	
risk management	. 	
(1) Environmental laws and regulations are incomplete	, and 	the environmental 	
judiciary is still at 	an	 early stage	 	
After several major environmental incidents, China has s	tarted to develop relevant laws	. 	
Both 	the 	Emergency Response Law	 and 	the 	newly revised 	Environmental Protection 	
Law	 put forward the principle of 	“Prevention as priority with combination of prevention 	
and emergency response	.” 	It 	clarified the environmental risk management 	
responsibilities on the part of governments at all levels, departments	, and enterprises. 	 	
Individual laws such as 	the 	Water 	Pollution Control Law	 and 	the 	Solid Waste Pollution	 	
Control Law	 have special provisions for “environmental pollution accidents response	.” 	
They 	state the requirements 	for	 site selection and layout of pollution emission 	
enterprises, prevention and emergency response preparedness, response and restoration.	 	
Preliminary revisions 	to 	the 	Air Pollution Prevention and Control Law	, which will be 	
implemented in 2016	, incorporate ri	sk 	management 	issues.	 	
Overall, h	owever, the system of environmental risk management law and regulation is 	
incomplete. First,	 legal 	gaps still exist. For example, the lack of an 	environmental 	
liability 	law	 prevents 	the 	determination of liability and compensation 	for damage 	
following 	environmental pollution events. A	nd	 there is a lack of relevant laws and 	
regulations related to soil environment protection, contaminated sites remediation	, and 	
re-use management. E	xisting en	vironment	-related laws and regulations 	address	 	
environmental risk	 issues to some extent, 	but	 relevant 	provisions	 are not 	specific 	or 	
clear 	enough	, and their operability is low.	 	
The e	nvironmental judiciary is 	an	 important guarant	or that	 environmental prote	ction 	
laws and reg	ulations can play their roles and be enforced. 	China’s 	first 	environmental 	
protection	 court was established in Qingzhen	 City in	 Guizhou 	province	, in 2007. 	By	 the 	
end of 2014 there had been more than 300 environment resource 	trial	s, 	colleg	ial panel	s, 	
and 	circuit court	s. The Environment Resource T	rial 	Court	 under 	the Supreme People's 	
Court	 was established in July 2014. 	 	
So, a	n initial e	nvironmental judiciary	 system has been established	 in China; h	owever, 	
it cannot 	yet 	play its role	 well.	 There is a lack of professional 	judiciary	 human resources	, 	
and e	nvironmental 	judiciary 	capacity	 needs to be improved	. 	
 (2) There 	is no	 unified	 environmental risk information data	base and data sharing	 	
system	 	
Providing and sharing information is essential for	 the improvement of environmental 	
management. Currently,	 there 	is no overall coordinated approach to 	the 	management 	
and sharing of environmental risk and 	management information.	 Each 	government

24 	
department involv	ed with	 environmental issues	 ─ environmental	 protection, 	water 	
conservancy	, ocean	, meteorology	, land and resources, agriculture	, and so on ─ 	has one 	
or more sets of data	 but	 no	 unified data interface	, data 	sharing mechanism	, or basic 	
database	. D	ata redundancy and conflicts	 exist	. 	
Even inside 	environmental protection departments, data sharing	 is weak. This means 	
that 	the 	information 	requirements for environmental risk assessment and management	 	
cannot be met	. During 	an 	emergency response, weak data sharing may affect the 	
implementation of the 	response measures	. Thus it is necessary	 to integrate the data from 	
different departments and develop a unified environmental risk information system 	that 	
can be shared across departments.	 	
In addition, 	basic data	 about 	environmental risks	 are	 still lack	ing. F	irst, there 	is 	no 	
exposure information 	for 	environmental risks 	such as 	numbers	, distribution	, and 	
location	 of contaminated 	and high hazard 	sites, concentration data 	for 	emerging 	
pollutants,	 and so on	. Second, research on exposure	-response relationships between 	
environmental risk factors and receptors 	is 	still weak	 with a consequent 	lack	 of	 	
exposure response information, 	for example	, environmental baselines 	relating 	to human 	
and 	ecological health	. 	
In 2015 t	he State Council issued th	e 	Construction Plan for Eco	-environmental	 	
Monitoring	 Network	 to address 	these issues: 	the 	incompleteness 	of the scope and 	
elements covered by 	the 	current eco	-environmental monitoring network	; the lack of 	
unified data construction plan	s, standards, and 	information disclosure	; gaps in 	
information sharing	; and 	the 	low 	quality of 	monitoring data. This new plan proposes to 	
establish an eco	-environmental monitoring 	“big data	” platform, and to establish 	
mechanisms for eco	-environmental monitoring data integrat	ion, sharing, and u	nified 	
disclosure. The plan provides a good opportunity for environmental risk data to be 
incorporated and integrated into this system.	 	
 (3) 	A s	ystem of f	inancial instrument	s for environmental risk management	 has not 	
been developed	 	
China is still 	at an early stage of using financial instruments in environmental 	
management, 	although it has seen 	certain achievements. For instance, 	in 2007 	MEP and 	
the 	China Insurance Regulatory Commission (CIRC) jointly issued the 	Guidance on 	
Environmen	tal Pollution Insurance	 and 	in 2013 	conducted a series of pilots, and 	then 	
issued a follow	-up 	Guidance on Pilots of Mandatory Environmental Pollution 	
Insurance	. 	
The current financial instruments for environmental risk management still have many 
problems, 	however, 	and the system is incomplete. First, there 	is no 	mandatory legal 	
requirement for financial assurance at a national level	. T	he new 	Environmental 	
Protection Law	 will only 	“encourage enterprises to buy environmental pollution 	
liability 	insurance	,” al	though some provinces have adopted some form of insurance	 	
pilots	. Such mandatory requirements	 need to be specific to ensure that they respond to 	
the risks to be managed. 	Second, the value of 	the 	environment and 	natural 	resources 	
has not been commonly recog	nized 	in the 	current econom	ic system	. E	nvironmental 	
financial instruments 	cannot	 be well integrated with current financial system	s, a fact 	
that 	has 	hindered the development of 	financial instruments for environmental risk 	
management.

25 	
In addition, there is 	a lack of technical directives and guidelines to support pollution 	
liability financial assurance.	 For instance, even though MEP and CIRC jointly issued 	
Technical Guidelines of Environmental Risk Assessment 	– Environmental Risk 	
Classification for Chlor	-alkali Sector 	and 	Technical Guidelines of Environmental Risk 	
Assessment 	– Environmental Risk Classification for Sulfuric Acid Enterprises (trial)	, 	
there are large gaps in 	sectoral coverage,	 and 	a lack of appropriate 	provisions 	to assist 	
in 	determin	ing	 pre	mium rate	s, liability limits,	 damage	 verification	, or 	compensation.	 	
 (4) 	Environmental risk emergency response capacity is weak	 	
China has 	established 	an initial	 emergency response preparedness plan network 	
including national, special, 	and 	departmental	 plans	, plans for 	local institutes and 	
enterprises	, 	and temporary preparedness plans	. 	Th	ese	 	constitute an overall 	
environmental emergency response plan management system	. Nonetheless, 	the overall 	
levels and 	operability	 of 	emergency response	 plans in China 	are relatively low. Most of 	
the responses to environmental emergencies have shown that 	joint emergency response	 	
across regions and departments is insufficient, i	nformation collaboration	 is 	inadequate	, 	
equipment and technologies for emergency monitoring, ea	rly warning, and disposal 	
remain 	weak, 	and 	the 	operability of emergency response plan	s is poor.	 It 	is necessary	 	
to 	increase the capacity for environmental emergency response to the 	same 	high level 	
of capacity 	exist 	for natural disaster response	 in China	. 	
MEP released the 	Measures	 of 	Accidental 	Environmental Event Emergency	 	
Management	 in 2015, which requires that 	enterprise	s, 	public institution	s, and 	
environmental departments at all levels conduct regular 	emergency	 response	 exercises	 	
based on the emergency response plans, write 	exercise evaluation report	s, analyse 	
existing problems	, improve the	ir emergency plan	s based on the 	exercises	, and 	publicize 	
their response plans and exercises. The implementation of this regulation will improve	 	
the 	operability	 and overall level	 of emergency response 	plans 	in China. 	However, there 	
remains 	a lack of relevant guidelines and e	ffective 	punitive 	and incentive	 measures 	that 	
will	 drive and facilitate emergency response exercises and revisions to plans.	 	
 (5) 	Weak 	industry and enterprise responsibility 	 	
Analysis of the m	ain 	causes for 	environmental 	pollution i	ncidents	 in chapter 1 shows 	
that	 low 	awareness of 	environment	al res	ponsibilit	ies	 and	 violations of laws and 	
regulations by 	industries and	 enterprise	s are the main reasons.	 From the perspective of 	
environmental management, increas	ing	 the compliance level of China’s enterprises 	is 	
a long	-term challenge.	 Therefore, building 	a corporate environmental risk responsibility 	
system, adjusting relationship	s between government and enterprises	, creating economic 	
incentive instruments such as taxes, fees	, and tradable quotas, 	and stimulating 	the 	
inherent vigour of enterprises to lower environmental risk	s, are	 important pathway	s for	 	
a new model of environmental 	management.	 	
Since the adoption of 	the 	ISO1400	1 international environmental management system 	
standard	, many international enterprises have 	improved their 	internal 	environment, 	
health	, and safety (EHS) s	ystem	s, thus lowering corporate 	environmental	 risk an	d social 	
cost. 	With the	 more recent 	ISO26000	 corporate social responsibility (CSR) guidelines	, 	
many enterprises 	are 	consider	ing	 the implementation 	of 	CSR 	practices 	as 	being 	
important for their 	business	. Many enterprises in China 	have 	established 	their 	EHS

26 	
system	s and have 	also 	gradually implemented 	a CSR strategy	, f	or example,	 SINOPEC 	
and 	the 	Shenhua Group.	 	
M	ost enterprises	, however,	 do not have 	a strong motivation to establish	 an 	int	ernal EHS	 	
management	 system. 	This 	gap 	has been reflected in the 2015 Tianjin 	exp	losion 	accident, 	
where 	insufficient information disclosure for hazardous chemicals 	contributed	 to 	
improper emergency response. 	Regulations like the Seveso Directives in the EU 	could 	
provide a possible model	 for 	Chi	na.	 	
2.5 Weak E	nvironmental 	Risk 	Communication and 	Engagement 	System 	 	
China is in a stage of transformation 	in which the 	traditional environmental risk 	
management 	approach	 is no longer compatible with modern risk management 	
requirement	s. First, environmental risks are becoming more 	widespread, 	divers	e, and 	
complex. More than ever, environmental risk management 	requires	 more cooperation 	
among departments	, across 	government	s at all levels	, and with the 	public	 at large. It 	
also requires	 mor	e flexibility to adapt to local natural and socioeconomic situations, 	
and more modern information technologies.	 It is essential to e	stablish	 an	 environmental 	
risk communication 	system	 with 	the 	participation of government, enterprise	s, and 	
public 	organizati	ons 	through information 	sharing, 	disclosure	, and public participation 	
in risk management	. This	 is an inevitable choice 	for the	 rule of law in China.	 	
In 2006, China’s 	State Environmental Protection Administration 	(now MEP	) released 	
the 	Temporary 	Measures o	f Public Participation of Environmental Impact Assessment	 	
which facilitated and 	normalize	d p	ublic 	participation	 in EIA. 	Measures of	 	
Environmental 	Information 	Disclosure	 (trial	) released in 2007 facilitated and 	
normalize	d the e	nvironmental 	information 	disclosure	s of 	environmental protection 	
department	s and enterprise	s. The 2015 	Environmental Protection Law	 has a chapter on 	
“information disclosure and public engagement” which 	explicitly sti	pulates that 	
citizens, 	corporation	s, and other organizations have 	the right to obtain environmental 	
information and to participate 	in 	and oversee environmental protection issues	. 	
Furthermore, it stipulates that 	environmental protection departments at all levels, other 	
departments which have environmental protection dutie	s, and major 	pollut	ant 	
discharging unit	s should disclose relevant environmental information. MEP released 	
the 	Measures of	 Public Engagement in Environmental Protection 	as the supplemental 	
regulation to the 	Environmental Protection Law	 in the same year, which 	stipulate	s the 	
rights and ways for public participation in environmental protection. 	 	
Thus, p	reliminary environmental information disclosure and public engagement 	
systems have been established. However, some problems	 still exist	: 	
(1) 	Current 	laws and regulations are mainly for environmental protection departments	. 	
They	 lack provisions for information integration, sharing, and disclosure across 	
ministries. 	Although the 	Measures of Environmental Information Disclosure for 	
Enterprises 	and Public Institutions 	was	 released in 2014, there 	remains 	a lack of 	
supporting and operable punitive and incentive policies and regulations	 for information 	
disclosure by enterprises. This has 	led to poor implementation of environmental 	
information disclo	sure and public engagement	 by enterprises	. 	
(2) An effective and responsive environmental risk communication and negotiation 
system has not been established. There are 	few	 provisions 	or 	specific plans to ensure

27 	
that environmental risk level	s remain within 	those	 that the affected populations regard 	
as acceptable. 	Communication and engagement can help 	inform the public and elicit 	
public preferences	 that will 	bring official policies on acceptable risk	 levels in line with 	
what social groups and the public at la	rge expect. Communication can also help adjust 	
risk perceptions	 to the local economic 	situation and political standards. 	Meanwhile, 	
education and training in the field of	 emergency management	 is 	lacking	, including	 for 	
self	-rescue, evacuation, and damage av	oidance 	by members of the 	public, especially 	
vulnerable people.	 Communication is an integral part of emergency 	response 	education. 	
It can inform people how to behave in emergencies and crisis situations. This is 
particularly	 important for vulnerable people	 such as the elderly	. 	
(3) 	The 	Measures of Public Engagement in Environmental Protection	 offers 	citizens	, 	
corporations, and other organizations	 the 	right to engage in 	policy making	 and 	to 	
oversee	 illegal behaviour 	by 	corporations and other organizations	. However, concrete 	
ways, measures, and procedures 	for	 public engagement are still lacking. 	Public 	
engagement is a mere formality	. A 	discussion is	 ne	eded to specify what type of policy 	
should 	be open for public debate and engagement	. China	 also lacks provi	sions 	on how 	
to incorporate stakeholders into policy making procedures.

28 	
CHAPTER 3.	 INTERNATIONAL EXPERIENCES OF ENVIRONMENTAL 	
RISK MANAGEME	NT	 	
 
3.1	 The 	history 	of environmental risk management systems in 	developed	 countries	 	
A number of	 countries	 have established robust and systematic environmental risk 	
management systems	. For example the Netherlands, the U	nited 	Kingdom	, the 	United 	
States	, Canada, Australia, New Zealand, Singapore, and South Korea all have strong 	
risk assessment systems and risk	-based policy regimes. 	Their 	history	 shows 	however 	
that the	se risk control 	systems were 	only 	gradually developed	, driven by a series of 	
major polluti	on acci	dents or events, 	and 	or by 	longer	-term chronic pollution 	during their 	
process of	 industrialization. 	 	
In the 	US	, for	 example, there were several photochemical smog incidents	 in 	the 	1940s	 	
and 	1950s in 	the Northeast	 and 	in 	Southern	 California. The smog 	spurred 	the 	
development and implementation of the US 	Clean Air	 Act	. By the 1970s, after 	several 	
amendments of the 	Clean Air Act	, the law	s and regulation	s governing	 air pollution 	
control and risk prevention were established. The 	Act	 requires US E	nvironmental 	
Protection 	Agency	 (EPA)	 to set national ambient air quality standards (NAAQS) 	and 	
other policies 	to prot	ect public health and welfare. 	 	
Similarly, the 	Clean Water Act	 (1972) was enacted after crises at Lak	e Erie and the 	
Cuyahoga River. 	Another example is the Love Canal crisis (1978), which spurred the 	
enactment of 	the 	Comprehensive Environmental Response, Compensation, and 	
Liability Act	 (CERCLA, also called 	the 	Superfund Act	) in 1980. A series of t	echnical 	
guidelines	 were developed under the superfund system. 	A national priority list of 	
contaminated sites 	that	 threaten harm 	to human health and 	the 	environment was also 	
developed. 	While 	much 	remediation was achieved and	 risk management system	s for 	
contaminated	 sites 	established	, studies have shown that CERCLA	 has required 	clean	-	
up	 of low	-risk sites at a very high cost.	 	
In Europe the development 	of these systems 	has also been event	 driven 	following 	the 	
great smog of London in 1952, the Seveso disaster of 1976	, and the Sandoz chemical 	
spill of 1986	. All these 	events led to more stringent regulation.	 	
Risk prevention is an important principle of environmental legislation in 	European 	
Union (	EU	) countries. Environmental risk assessment is considered one of the bases	 for 	
applying environmental risk prevention. Relevant legislation mainly 	focused on 	worker 	
safety and health protection, then gradually shifted to environmental pollution 
prevention and response. The 	EU’s 	Maastricht Treaty	, promulgated in	 1992	, and raised	 	
risk prevention to 	the level of 	constitutional principle. The Bulletin on Environmental 	
Risk Prevention Principles passed by 	the 	EU in 2000 provided a clear and effective 	
guideline for environmental risk prevention, especially risk assessment. Meanwhile, t	he 	
EU 	has 	developed a series of specific laws and directives to provide further regulation 	
on 	the 	risk management of industrial activities, corporate environmental risk, 	and 	water 	
environment, human health	, and ecosystem maintenance	. 	
Driven by a series of environmental pollution events, 	the 	US gradually established 	a 	
robust	 environmental risk management system	 – though it continues to debate 	about

29 	
and reform its system	. During the process, 	the 	US Environmental Protection Agency	 	
(EPA)	 and US 	National Academy of Sciences	 (NAS)	 continually	 worked to 	rethink and 	
research environmental risk assessment tools,	 all of 	which 	advanced 	environmental risk 	
assessment and management	 approaches	. For example, 	in 1994, NAS published 	Science 	
and Judgment in Risk Assessment 	(the 	Blue Book	) which 	evaluated the	 deficiencies of	 	
environmental risk management tools (including environmental risk assessment 
methods and procedures, priority setting methods, data acquisition, and risk 
communicat	ion)	. This 	tool 	was	 used by 	the 	EPA for toxic air contaminants management	. 	
In 	2009	 NAS published 	Science and Decisions: Advancing Risk Assessment	 (the 	Silver 	
Book	). The report 	conducted a review and evaluation of risk analysis and assessment 	
approaches used by 	the 	EPA	, and	 offer	ed	 recommendations for practical improvements 	
that 	the 	EPA could make.	 	
Overall, 	the robust	 environmental risk management systems in European 	countries	 and 	
the United States and Canada	 provide useful 	lessons 	for	 China.	 It should be noted 	
however 	that the 	establishment of these 	systems 	was 	driven 	by a combination of 	
pollution accidents	, the demonstration of chronic health	 and ecosystem effects of 	
chemicals	, air and water pollution	, and soil and water pollution from contaminated sites	. 	
Thus	 the establishment	 and	 improvement of	 such 	sy	stem	s should not be event	-driven 	
but 	instead 	should be guided by 	a strategy	 which incorporate	s accidental, acute 	
threshold	, and chronic environmental risks from a range of sources	. Further	, the 	
development of environmental risk assessment system	s suggests that	 there needs to	 be 	
ongoing	 re-evaluat	ion	 and improv	ement of 	the risk management system 	to adapt 	to 	
changes 	in risk 	con	ditions	. 	
3.2 International 	Experiences 	of 	Environmental 	Risk 	Governance	 	
(1)	 Vertical 	risk 	responsibilities and 	integration	 	
In the US, several agencies are responsible for risk assessment and management, 
including the EPA, the Department of Energy,	 the 	National Oceanic and Atmospheric 	
Administration (NOAA),	 the Department of Agriculture, the F	ood and 	Drug 	
Administration	, the Occupational Safety and Health Administration, the Department of 	
Transportation, the Nuclear Regulatory Commission, and the Department of Homeland 
Security. 	In 	each of 	the 50 states,	 state	-level	 environmental protection agencies, 	
agriculture agencies	, food and drug management agencies	, and commodity inspection 	
agencies are responsible for state	-level environmental risk assessment and management. 	
The state	-level 	environmental 	bodies receive supervision from EPA regional offices, 	
and often are delegated	 authority by 	the 	EPA to implement federal laws	 ─ 	subject to 	
national oversight and enforcement by 	the 	EPA	 ─ 	in a system of “cooperative 	
federalism.” 	 	
In the EU, EU	-level institutions adopt policies that need to be “transposed” into member 	
state law	. W	ithi	n almost all EU 	member countries the national environmental ministry 	
supervises environmental protection at 	the 	local level through regional offices. 	 	
 (2)	 Horizontal 	risk 	responsibilities 	and 	integration across 	ministries	 	
Fragmentation across agencies is 	a challenge even in the most developed regulatory 	
systems. As just noted, in the US multiple federal agencies manage multiple risk 
domains. This horizontal proliferation of agencies and missions can make priority	-

30 	
setting difficult, and can lead to tradeoff	s in which reductions in one risk by one agency 	
unintentionally yield increases in other risks under the domain of another agency (or 
failure to attain the co	-benefits of reducing multiple risks in concert). The EPA has 	
special authority over many environ	mental laws, and working relationships with other 	
national departments with environmental risk responsibilities. For instance, relevant 
federal departments must provide environmental impact statements on new projects, 
and the EPA has the authority to revi	ew these statements and recommend improvements. 	
But the major mechanism for horizontal coordination across US agencies occurs at the 
White House (cent	re of government)	. 	
In other countries, the use of environmental risk in decision making has also been 
grow	ing. The system in Norway is noteworthy for its integration of macroeconomic 	
planning models and environmental scenarios. The Norwegian model informs policy 
makers and advisers in the 	ministries of f	inance, 	industry, e	nergy	, and 	environment 	
about the 	consequences for environmental risk of macro	- and sometimes micro	-	
economic policies in the country.	 	
In the EU, there are also agreements to share environmental data, and institutions are 
legally bound to submit data to central institutions such as the Nati	onal Statistics 	
Bureaus. The European Environmental 	Agency	 provides recommendations to member 	
countries on policy development and decision making on environmental protection, and 
promotes environmental information communication among member countries, as w	ell 	
as environmental monitoring. The Environment Department of the European 
Commission (DG XI) is responsible for coordinating development of environmental 
quality standards, developing	 and 	revising environmental laws and regulations, and 	
ensuring enforcem	ent and implementation of relevant environmental policies. The 	
science and technology department (DG XII) is responsible for providing support to 
policy making on environment, health, education	, and energy. The Minister of the 	
Environment is part of the ca	binet in most EU member countries. Environmental 	
ministries in several countries have set up internal departments based on environmental 
elements or media (air, water, soil, biodiversity). 	 	
(3)	 Environmental 	risk 	board	s 	
To reinforce the importance of build	ing environmental risk into decision making	 ─ 	and 	
to ensure national oversight of risk management	 ─ 	the establishment of “national risk 	
boards” is emerging, and a 	few countries have taken this step. The World Bank, in its 	
annual World Development Report 	(2014	)23	, included as its first policy 	
recommendation that every country should establish a National Risk Board. The 	World	 	
Bank report 	citing 	earlier 	reports	 24,25 argued that countries often face numerous risks 	
but have fragmented institutional structures fo	r responding to those risks. 	One	 result of 	
such fragmentation is that different risks are addressed separately, with little 
coordination, leading to skewed priority	-setting and to poor risk tradeoff decisions 	
(where efforts to reduce one risk unintentional	ly induce other risks, or shift risks to 	
 	 	 	
23	 The World Bank (2014). “Managing Risk for Development.” (pp.278	-279). World Development 	
Report 2014	 	
24	 John D. Graham & Jonathan B. Wiener (1995)	, Risk vs. Risk, Harvard University Press	 (chapter 11, 	
“Resolving Risk Tradeoffs,” 	pp.257	-260)	. 	
25	 World Econom	ic Forum (2007). Global Risks Report.

31 	
other populations	, or fail to attain co	-benefits	). Fragmented agencies also may lack 	
mechanisms for longer	-term foresight of emerging risks outside their domains.	 	
A national risk board can help address these proble	ms of fragmentation and provision 	
of foresight by coordinating across the complex institutional structure and varying 
challenges of risk assessment and management. Its role can be advisory to official 
government policy makers, or it can have a more influen	tial or even official role in 	
shaping policy itself. Its membership can consist of experts outside of government, or 
government officials, or a mix of these a	nd other types of participants.	 	
Several countries have established versions of a national risk 	board. The US has created 	
a White House Office of Information and Regulatory Affairs (OIRA), which oversees 
and coordinates across federal risk regulation	 and reviews cost	-benefit analyses of 	
federal regulation	. The EU has created an Impact Assessment Boar	d (IAB) located in 	
the Secretariat General, and recently renamed 	it 	the Regulatory Scrutiny Board, to 	
oversee and c	oordinate regulatory policies. 	Singapore 	ha	s the strongest example of a 	
fully national risk board, including risk assessment, horizon	-scannin	g foresight, a	nd 	
priority	-setting functions. 	The country takes a “	whole	-of-government 	integrated 	risk 	
management” approach, advised by a Centre for Strategic Futures (now called the 
Strategy Group in the Prime Minister’s Office) and a Risk Assessment Horiz	on 	
Scanning (RAHS) office located in the National Secur	ity Coordination Secretariat.	 	
In addition, 	the US and 	several countries	 in Europe 	have established post	-crisis	 or post	-	
disaster investigation bodies or “safety boards.” In many cases, such post	-crisi	s 	
investigations are conducted by one	-time, 	ad hoc	 commissions of inquiry, which can 	
focus high	-level attention on a major event (such as the US 9/11 Commission, and the 	
US Deepwater Horizon Oil Spill Inquiry Commission), but these 	bodies 	lack the 	
permanen	t expert staff, the historical perspective, and the credibility that come with 	
repeat	ed	 investigations over many incidents over time. Thus, some countries have gone 	
further to establish permanent, independent post	-crisis/disaster investigation bodies. A 	
ne	w study 	examines 	these national safety boards	26. Strong examples include the single	-	
sector US National Transportation Safety Board (NTSB), and the multi	-sector Dutch 	
Safety Board (DSB).	 	
(4)	 Roles of 	scientific 	institutions	 	
Scientific institutions play a 	critical role in determining the facts behind the assessment 	
and management of environmental risks. They can provide valuable input to the work 
of environmental risk boards and government policy makers. The EU has designated 
and tasked science	-based instit	utions with bringing forward the factual basis for 	the 	
regulation of environmental risks and advising on the environmental benefits (lower 
risk) of regulation. An example is the International Institute of Applied Systems 
Analysis (IIASA), based in Austria,	 which provides the scientific basis for air quality 	
management in Europe. 	 	
Similar organizations providing the scientific basis for risk assessment and 
management exist in the US	 states, such as 	NAS, 	the Centre for Disease Control 	and 	
 	 	 	
26	 Edward Balleisen, Lori Bennear, David Cheang, Jonathon Free, Megan Hayes, Emily Pechar, and A. 	
Catherine Preston (2015), “Institutional Mechanisms for Investigating Crises and Regulation 
Reassessment: The Commission 	of Inquiry and the Safety Board” (	in E. Balleisen et al., eds, Policy 	
Shock, Cambridge Univ. Press,) forthcoming.

32 	
Prevention 	CDC), 	the	 National Institute of Environmental Health Sciences (NIEHS),	 	
the National Oceanic and Atmospheric Administration 	(NOAA), 	the research office of 	
the EPA, 	and the 	national labs of the 	Department of Energy	. By means of transparency 	
in operation, inclusivenes	s in participation	, and scientific integrity, these institutions 	
have earn	ed	 the respect of policy makers as advisors on the factual basis of regulation 	
of environmental risk.	 	
3.3 International 	Experiences 	of 	Environmental 	Risk 	Goals and 	Strategy	 	
(1) 	Setting 	goals	, targets	, and 	acceptable 	risk 	levels	 	
The US 	Clean Air Act	 (CAA) 	as amended in 1990 incorporates 10	-6 risk frequency into 	
Section 112 as the residual risk level for hazardo	us air pollutants (air toxics)	 in Section 	
112	. But this	 quantitative 	probability level	 is unusual	 among US laws	. And it is not the 	
main regulatory requirement in Section 112 	under which 	maximum avai	lable control 	
technology, 	or 	MACT 	must be applied first. Besides Section 112, in other areas of the 	
CAA, such as those 	addressing national ambient air quality standards (NAAQS)	 and 	
other US laws, do not	 generally define 	a quantitati	ve risk level.	 Instead, 	US laws often 	
instruct EPA to “protect public health” or “prevent unreasonable risk,” and leave it to 
EPA 	to determine 	the quantitative risk level 	in specific polic	ies	. 	
The most elaborate approach to assessing and determining environmental risk in the 
EU is found in the case of classical air pollutants. Air quality guidelines for these 
pollutants are based on the impact p	athway approach. This approach allows an estimate 	
of 	risk of 	environmental damage associated with exposure and also 	expected 	reduced 	
damage (	that is,	 benefits) from reduced exposure. The actual emission levels are the 	
results of negotiations that take cost	s as well as benefits into account. For hazardous 	
chemicals the approach is cruder. In Europe the REACH directive specifies 	“substances 	
of high concern	.” 	
An influential study	27 found a wide variety of quantitative risk levels espoused in 	
different US laws with many different levels	 or 	standards.	 A more recent study surveyed 	
the actual regulation of many risks in the US and Europe and found no consistent 
principled approach to pr	ecaution	. R	ather, it found a complex pattern of different 	
degrees of precaution addressed to different risks	28. 	
Annex 	Table 	5-1 provides the risk goals under various laws and regulations in the US 	
and the EU. These are variously expressed in quantitative, q	ualitative, or technology 	
terms.	 	
In the US and Europe, consideration of 	cost	-benefit and 	cost	-effectiveness also guid	e 	
the determination of targets for environmental risk reduction. Cost	-benefit	 means that 	
the 	optimal level of risk reduction is selected by	 weighing the	 marginal benefit of 	
environmental risk reduction against the marginal cost of risk reduction. 	Cost	-	
effectiveness means that a given level of risk reduction is achieved at least cost. 	The	se	 	
principle	s are	 often presented in 	legal	 language such	 as 	the benefits should justify the 	
costs, or seek to 	maximize net benefits, or aim	 for environmental risk to be as low as 	
 	 	 	
27	 Alon Rosenthal, George Gray and John Graham, “Legislating Acceptable Cancer Risk from Exposure 	
to Toxic Chemicals,” 19 	Ecology Law Quarterly	 269	-362 (1992)	 	
28	 J.B. Wiener, M.D. Rogers, J.K. Hammitt & P.H. Sand, eds., 	The Reality of Precaution: Comparing 	
Risk Regulation in the US and Europe (RFF Press/Earthscan/Routledge, 2011)

33 	
reasonably practicable	, prevent unreasonable risk, 	protect public health using the least 	
burdensome alternative, minimize 	risk given 	due consideration of cost, or best available 	
technology given due consideration of cost	. 	
(2) 	National 	assessment and 	strategy	 	
The main goal of national risk assessments is to 	identify current and emerging risks, 	
estimate their seriousness, and contribute to setting 	priorities. Risk assessments provide 	
a numerical or at least a qualitative basis for judging the 	likelihood, 	seriousness	, and 	
distribution of expected damages over t	ime. 	A risk 	assessment 	seeks to measure	 the 	
product of probability and outcomes, 	and helps estimate the 	benefits 	of reducing risks 	
and the distribution of these expected benefits 	across	 target groups (for example 	
children, elderly people, poor people,	 and 	so on	). 	
As a complement to the science	-based risk assessment, it is prudent to conduct a 	
concern assessment	 among major stakeholders (industry, citizens, social organizations) 	
to explore their risk perceptions and concerns. 	Public concerns may differ from	 expert 	
risk assessments, potentially due to heuristic 	strategies of	 public	 perception.	 Depending 	
on the outcome of the concern assessment, different management and communication 
strategies should be designed and aligned to the risk management options that	 are 	
derived from the priority setting exercise of the responsible decision making agency.	 	
When setting goals and formulating strategies for risk reduction, international 
experience has shown that it is essential to involve the public 	─	 as per the guidelines 	
of the International Risk Governance 	Council (IRGC)	29 ─ to gain an	 understanding of 	
perceptions.	 	
Risk p	erceptions	 include four major 	triggers	: 	
a) 	Intuitive biases and heuristics that make a risk appear more (or less) serious than it 
actu	ally is	 	
b) 	Specifi	c areas 	such as food or drinking water quality that lead to heightened 	public 	
concern	. These very sensitive topics vary from culture to culture and often from 	
social group to social group	 	
c) 	High concerns 	may 	come from 	distrust 	of 	or lack of 	confidence in any of the crucial 	
actors involved (	for example, 	industry	 or regulators)	 	
d) 	High concerns can be used to develop a strategy to promote specific policies or to 
get public attention for an issue or a group (strategic motivation).	 	
It is essential to address these four elements of perceptions in risk management and risk 
communication	. Being sensitive to public concerns helps to gain acceptance of official 	
policies and to build up trust in management institutions. 	 	
 	 	 	
29	 International Risk Governance Council (IRGC). 2005. White Paper on Risk Governance: Towards an 	
Integrative Approach. Geneva: IRGC

34 	
3.4 International 	Experiences 	of 	Environmental 	Risk	 Enabling 	M	easures	 	
(1) 	Risk 	data and 	monitoring	 	
The European Environmental Agency (EEA) 	in Copenhagen 	is developing a European 	
Environment Information and Observation Network (	Eionet	) with the aim of providing 	
quality data, 	information, and expertise for assessing the state of the environment and 	
stress factors. This information will support information dissemination	 and	 the 	
development of policies and measures, and enable them to be monitored for their 
effectiveness. 	Eionet	 will provide systematic, nationally validated, high	-quality 	
environmental data.	 	
The US EPA, and the US government generally, collects extensive data on overall 
environmental quality indicators (	for example, 	e.g. ambient air and water pollution), as 	
well a	s on the environmental impacts of 	each source of pollution (e.g. 	such as e	missions 	
and discharges from private firms, and environmental impacts of government 
programs). EPA also operates several information disclosure requirement programs, 
such as the Toxi	cs Release Inventory and the Greenhouse Gas Reporting Rule.	 	
(2) 	Economic 	instruments	 	
Environmental taxes and fees are used in Europe and the US mainly in energy 
management and air pollution risk control. Risks from water pollution are mainly 
regulated by p	ermit. Risk of losing biological diversity is regulated in Europe by zoning 	
(similarly to ecological red lines), but there are some financial instruments and 
incentives towards farmers and to a lesser extent fishermen.	 	
Europe in particular regulates consum	ption of fossil fuels	 ─ an important precursor to 	
risk from air pollution	 ─ and CO	2 by economic instruments. In the context of 	
environmental risk, the lowering of fossil energy consumption and CO	2 emissions 	
implies lower emissions of particulate matter, mercury, SO	2, NO	X and other air 	
pollutants. 	 	
The US has long used tradable emission permits for 	air pollution control, including for 	
lead, 	chlorofluorocarbons	 (CFCs)	, and 	SO	2 emissions control. Th	e SO	2 tradable permits 	
syste	m, 	adopted in the 1990s,	 is considered a success story that has been cost	-effective 	
and 	has 	achieved considerable emission	s reduction, hence lowering environmental risk 	
to health and ecosystems. 	The 	low cost made possible by the trading system enabled 	
the 	ambition for emission	s reductions 	to be tightened 	in several rounds	 over time	. The 	
EU then adopted after 2001 a tradable permit system to reduce greenhouse gases,	 ─ the 	
EU Emissions Trading System (E	TS).	 	
(3) 	Financial 	security 	instruments for 	environmental 	risks	 	
Financial security instruments 	(FSI) 	include secured funds, on	-demand performance 	
bonds, company guarantees, and insurance. These financial solutions are available to 
industrial operators and	 to government agencies. Financial security requirements may 	
be applied on a sectoral basis, 	to 	industrial activities with 	the 	highest level of risk, 	for 	
example, 	or on a regional or national level. They may incorporate risks associated with 	
normal 	or abnormal 	operations,	 such as	 during accidental or natural hazard events.

35 	
A range of American	, European, and Asian countries have adopted FSIs) for 	
environmental risk management. These are used to fund 	the 	prevention of 	
environmental risks and remediation of 	damage to the 	environment. Some 	FSI’s, such 	
as insurance,	 have the added benefits of encouraging loss	-reduc	tion	 and 	risk prevention 	
behaviour. 	Environmental pollution liability insurance was first adopte	d in the US in 	
1966, and now has become a relatively complete system. Special environmental 
protection insurance companies were also established in 1988. The 	entire EU has 	
adopted environmental liability systems supported by 	encouraging the use of 	financia	l 	
security instrument	s since the Environmental Liability Directive came into force	, some 	
on a voluntary basis, some mandatory. 	In 2016 	South Korea will introduce a 	
compulsory environmental insurance program for industrial companies that handle 
hazardous ch	emicals. 	 	
Some common themes and developments that arise from countries’ financial security 
systems are: mandatory or voluntary financial provisions; instrument choice including 
insurance, bonds	, and funds; default options for insolvency; establishing minimum 	
limits for insurance or bonds	; evolution of legislation from pollution	-centred to broader 	
environmental damage; and	, evolution of financial markets to incorporate risks.	 	
(4) 	Emergency 	respon	se 	
In the US, the Federal Emergency Management Agency is responsible for leading and 
supporting nationwide environmental risk emergency response. The country has 
established a national emergency management information system and a National 
Incident Managem	ent System (NIMS). It has issued a 	national 	response 	plan, and 	
established a comprehensive warning and emergency management system with the four 
key elements of prevention, response, remediation	, and mitigation. 	It also has special 	
emergency response syste	ms for oil spills, nuclear accidents, and other specific types 	
of accidents. And it has post	-accident investigation bodies, notably the NTSB and 	the 	
Chemical Safety Board	, to assess the cause and 	to 	recommend improved prevention 	
policies.	 	
In the EU, emergency response is guided by the REACH chemical registration 
requirements, the Seveso II and III 	directives, the EU civil prevention mechanism, and 	
the 112 emergency response mode. 	The Seveso directives that regulate production 	
facilities dis	tinguish between upper tier (high risk) and lower tier (low risk) facilities. 	
Upper tier facilities are regulated much more strictly. 	 	
More 	generally, there are two main characteristics of the EU environmental risk 	
management system related to accidents	. First	, close attention is paid to land use 	
planning, in order to prevent environmental accidents. Strategic environmental 
assessment is carried out for land use plans. Second, public participation is given 
priority and is a formal prerequisite in the plann	ing process. 	 	
In terms of emergency response, the International Commission for the Protection of the 
Rhine launched the Warning and Alarm Plan (WAP) in 1985. Within the framework of 
WAP, countries in the Rhine basin all established environmental warning ce	ntr	es. The 	
EU put the Major Accidents Reporting System (MARS 4.0) into operation in 2001 to 
help member countries make reasonable decisions in addressing major environmental 
pollution accidents.

36 	
Environmental risk management in Japan covers various kinds 	of natural environmental 	
incidents and man	-made environmental incidents. Japan established a national crisis 	
management system based on comprehensive disaster management, and formed a risk 
management system of “risk prevention and reduction	, crisis managem	ent	, and	 national 	
security	.” The country established a disaster prevention information system and 	
emergency response system at central and local levels	, and formed a horizontally and 	
vertically integrated disaster relief and emergency response information 	network. 	 	
(5) 	Industrial 	responsibility	 	
In Europe and elsewhere, governments and regulatory authorities have put in place 
incentives for environmental risk practices by enterprises. They 	emphasize to 	
companies the necessity and benefits of environmental 	risk assessment processes and 	
management as an integral part of an enterprise’s progress and success	. These processes 	
incorporat	e avoidance and management of hazards, opportunities for cost management, 	
positive influences on internal culture, marketability	 of green products, and tools to 	
communicate with stakeholders.	 	
Th	ese	 government measures may include recommending to companies the adoption of 	
international and national standards such as International Environmental Management 
Standards ISO 14000 series,	 Europe’s Eco	-Management and Audit Scheme (EMAS)	, 	
and Risk Management Standards ISO 31000 series. Other standards for environmental 
risk management include the Global Environmental Management Initiative (GEMI) and 
the 	International Finance Corporation	’s En	vironmental and Social Performance 	
Standards. 	Incentives for environmental risk planning by enterprises are also built into 	
the Seveso and REACH directives	 in Europe, and US laws such as 	the 	Clean Air Act	 	
112	. Some countries have put in place 	codes of 	prac	tice and 	standards such as Spain’s 	
UNE Standard 150008, Australia’s Sectoral Standards and Government Agency 
Environmental Network (GAEN), and the UK’s Pollution Prevention Guidelines 
(PPGs).	 	
Industrial sectors in Canada, the US, Europe and elsewhere have	 implemented 	
voluntary industry	-developed performance standards to manage environmental risks 	
and drive performance improvement. This 	has 	produce	d benefits which 	provide 	
incentives to	 industrial sectors to reduce and manage environmental risks, 	with benefits 	
including public safety, improved environmental performance	, reduced management 	
costs, increased	 community confidence, and reduced regulatory requirements. 	 	
Industry 	standards can be recognized in 	government	 regulations, providing further 	
inc	entive to the industry to adopt and achieve the standard. Examples of voluntary 	
standards programs include the 	Chemistry In	dustry Association of Canada’s 	
Responsible Care	 ® program	30; and, 	the Mining Association of Canada’s 	Toward 	
Sustainable Mining™	 initia	tive	31. The Responsible Care 	® program start	ed	 in the late 	
1980s in Canada 	and 	is 	now	 is a global, voluntary initiative developed autonomously 	
by the chemical industry	 in 52 countries	. C	ombined	, these	 chemical industries account 	
for nearly 90% of global chemical production, including in Hong Kong SAR and China	. 	
In China	, Responsible Care	® is a program of the Association of International Chemical 	
 	 	 	
30	 http://www.canadianchemistry.ca/respons	ible_care/index.php/en/index	 	
31	 http://mining.ca/towards	-sustainable	-mining/how	-tsm	-works/tsm	-verification

37 	
Manufacturers (AICM) registered in Hong Kong, which consi	sts of 50 international 	
chemical company members. State owned enterprises do not participate	32. 	
For European and American enterprises	, the setup of EHS (	Environment, Health, and 	
Safety	) departments and 	improvement	 of management 	systems 	has	 become a major 	part 	
of the	se companies’ 	sustainable development strateg	ies.	 	
(6)	 Environmental risks r	eporting	 in f	inancial 	reporting 	requirements	 	
A number of countries in North America and Europe have put in place rules for 
environmental risk disclosure through their 	securities exchange regulators, 	, integrating 	
environmental risk into financial reporting requirements. In Canada this is done through 
securities regulators’ rules for public disclosure	33. The US Securities and Exchange 	
Commission (SEC) also 	administers 	gui	delines on disclosure of environmental risks.	 A 	
new European Union directive on non	-financial (environmental and social) disclosure 	
by corporations has a similar 	purpose	34. 	
All t	his has built on 	the 	mandatory financial reporting of environmental risks in 	the UK	, 	
France, Germany and other 	countries	35. The Buenos Aires Stock Exchange has added 	
to its information disclosure requirements regulations 	requiring	 public companies 	to 	
include information about their environmental insurance	36. Disclosure is also a key 	
element of environmental 	measures 	in Europe	, for example in the Seveso and REACH 	
directives.	 	
3.5 	International 	Experiences 	of 	Environmental 	Risk	 Communication and 	
Engagement	 	
(1) 	Communication	 	
A major challenge 	for	 environmental	 risk management is that risk perception often 	
differs	 from statistically or experimentally derived numerical risk assessments. 	
Addressing this gap between 	public 	perception and 	expert assessment	 is one of the most 	
challenging tasks for inclusive risk gove	rnance. This can partly be addressed by 	
effective risk communication	37. Risk communication needs to address the physical 	
properties of a risk, the rationale for risk management options, the tradeoffs between 
risks and benefits as well as the agency’s respon	ses to people’s perceptions and 	
concerns. To accomplish all these goals is difficult	, and meeting the various demands 	
simultaneously often leads to value conflicts and communication contradictions.	 	
It is important to use targeted, two	-way public communicat	ions and engagement to 	
build public understanding of environmental risks. Transparent and effective 
 	 	 	
32	 http://www.icca	-chem.org/en/Home/Responsible	-care/Respons	ible	-Care	-Members/	 	
33	 https://www.osc.gov.on.ca/en/SecuritiesLaw_sn_20091218_51	-717_corp	-gov	-enviro	-disclosure.htm	 	
34	 http://ec.europa.eu/finance/accounting/non	-financial_reporting/index_en.htm	 	
35	 https://hal	shs.archives	-ouvertes.fr/halshs	-00658734/document	 	
36	 http://www.iclg.co.uk/practice	-areas/environment	-and	-climate	-change	-law/environment	-and	-	
climate	-change	-law	-2015	/argentina	 	
37	 US	-National Research Council (1989), Improving Risk Communication. Washington, D.C.: 	
National Academy Press. And: Fischhoff, B., N.T. Brewer and J.S. Downs. 2011. Communicating 
Risks and Benefits: An Evidence	-Based User ’s Guide. Report. Washington: US D	epartment of 	
Health and Human Services, Food and Drug Administration (FDA) 
(www.fda.gov/ScienceResearch/SpecialTopics/RiskCommunication/ default.htm).

38 	
communication of environmental risks between the policy maker and the public is 
necessary to:	 elicit the preferences and	 meet the demands of citizens affect	ed by 	
development	; and, 	build understanding of risks, including the differences between 	
perceived risks and assessed risk	. 	
Effective communication of risk will also build	 public and community confidence in 	
government	 ─ 	if this is supported by 	sensible	 regulation or other demonstration of 	
actions to reduce risks to citizens. 	Many 	international	 studies on risk management 	
emphasize the need for intensive risk communication between different agencies and 
decision	-making bodies. Even within an agency it is 	important to facilitate the dialogue 	
among 	risk experts such as toxicologists, cost	-benefit analysts	, and legal staff	 38. 	
International best practice guidelines for communication and cooperation among and 
between agencies 	have been proposed	39	. These guideli	nes should address the 	
transparency requirements of data and action plans, a protocol of who has to be 
consulted or informed prior to going public with a specific policy, and a documentation 
plan that requires a structured approach to set up a data bank an	d a workable archive 	
for all agencies involved. Respective agencies can establish a risk information sharing 
board that monitors the risk sharing practices and also determines what information is 
shared with a wider public.	 	
(2) 	Engagement	 	
One of the major tasks in policy making is the need to ascertain support by major 
stakeholders. Many of these stakeholders not only 	have a 	special interest in risk 	
reduction, they also have knowledge in risk reduction methods and practices. It is 
essential	 to include these groups in risk governance. Key stakeholders include: 	
scientists and experts; affected citizens; the private sector; and social organizations. In 
addition, one needs to take account of the public media as mediators between the policy 
level	 and the wider public.	 	
Public involvement can 	pursue the following functions	 40: 	
�x 	Enhancing transparency:	 Publish exposure data	. I	nform people ahead of time 	
of new developments or plans	. P	rovide all public bodies with the necessary 	
information 	so 	that they 	can act upon this information	. 	
�x 	Collecting feedback and preferences:	 Conduct surveys, set up focus groups, 	and 	
conduct	 dialogue sessions with social groups and representatives of the affected 	
public about their priorities, 	preferences,	 concerns	, and anxieties. Use this 	
information for both more effective risk communication programs	, inputs to 	
benefits valuation,	 and more sensitive risk management plans.	 	
�x 	Exercising and preparing people for emergencies	: Conduct regular exercises 	
and information pro	grams for making people familiar with appropriate 	
 	 	 	
38	 Löfstedt, R. (2001): Risk Communication and Management in the Twenty	-First Century. 	
International Publi	c Management Journal	 73: 335	–346	 	
39	 BfR (German Federal Institute for Risk Assessment) (2007)	. ERiK	 - Development of a Multi	-Stage 	
Risk Communication Process, edited by R.F. Hertel and G. Henseler.. BfR	-Wissenschaft 04/2007. 	
BFR: Berlin 2007.	 	
40	 OECD (2002)	. Guidance Document on Risk Communication for Chemical Risk Management. 	
Series on Risk management, No 16. Paris: OECD Press. And. Renn, O.: Risk Governance. London: 
Earthscan, p. 203

39 	
behavio	ur in emergency situations.	 	
�x 	Co	-designing policies:	 Include representatives of industry, social organizations	, 	
and citizens in monitoring or measuring exposure. Provide telephone or mobile 
phone hotl	ines for reporting events	. U	se formats of citizen participation for 	
urban and industrial planning.	 Consult stakeholder groups when preparing new 	
or revised policies.	 	
It is important to design public engagement policies in accordance with one or more of 
the four major purposes. Each purpose requires a different approach, different formats 
and moderation techniques. In the US 	and 	the EU	, dedicated 	private and public 	
inst	itutions have specialized 	in designing the most appropriate risk communication and 	
engagement program	s depending on purpose and risk	.

40 	
CHAPTER 	4. 	POLICY RECOMMENDATIONS 	TO ESTABLISH	 	AN 	
ENVIRONM	EN	TAL RISK MANAGEMENT SYSTEM IN CHINA	 	
 
This study proposes policy recommendations for 	building a 	proactive	 environmental 	
management system 	based on	 environmental risk	 prevention and reduction	. Such a 	
system will meet the basic needs 	of 	social and economic development and 	the 	eco	-	
environment, 	and will 	support the 	intrinsic requirement	s for construction and 	
implementation of China’s 	Integrated Reform Plan for Promoting Ecological 	
Civilization System	. It 	comprises	 four strategic elements: 	environmental risk 	
governance, 	risk	 goals and strategies, 	risk 	enabling 	measures, and environmental risk 	
communication and engagement	. Establishing and completing the 	environmental risk 	
management system will focus on the 	prevent	ion	 and 	reduction	 of the 	three categories 	
of environmental risks	 presented in 	chapter	 1. The basic framework for the	 system 	is 	
shown in Figure 4	-1. 	
 	
Figure 	4-1 Framework for 	the 	Environmental Risk Management System Based 	
on P	olicy	 Recommendations

41 	
4.1 ESTABLISH 	THE 	RISK	-BASED ENVIRONMENTAL GOVERNANCE 	
SYSTEM	 	
The recommendations in this study are founded on the urgent need to fully integrate 
environmental risk assessment and management into the environmental governance 
system of China at all levels. 	This will enable 	a proactive 	environmental management 	
approach	 focused on 	prevention and 	reduction	 of environmental risk	s to replace the 	
current reactive	 approach 	of environmental management	 with 	its	 focus on pollution 	
control	. By implementing 	these recommendations	 China has the opportunity to achieve 	
major 	improvements in environmental quality, human health	, and security.	 	
4.1.	1 Establish a 	High	-level	, Permanent National Environmental Risk Board	 	
China needs 	a high	-level	, permanent National Environmental Risk Board	 at the centre 	
of national government	. The 	responsibilities of th	is board	 would be to	: identify,	 assess	, 	
and prioritize current and potential environmental risks	 (sudden accidental, cumulative 	
threshold, and long	-term chronic risks	); help 	identify opportunities to reduce multiple 	
risks, and 	resolve tradeoffs 	among multiple risks and 	between economic development 	
goals and 	environmental risk control; 	coordinate	 and	 oversee environmental risk 	
management in an integrated way	; ensure evaluation of ongoing policies with a view to 	
learning and impro	vement over time	; and	, ensure 	that 	environmental risk assessments 	
are undertaken to inform	 major national economic, legal, and environmental decisio	ns	. 	
The 	board 	would 	provide the cornerstone for the national environmental risk 	
management system	. 	
The National 	Environmental Risk Board 	would 	mainly focus on environmental risk	, 	
but 	its work 	would be 	linked to other 	kinds of 	risks	 with strong environmental 	
interactions	, for example:	 natural disasters, 	food safety, workplace safety, and	 climate	 	
change	. Its responsibilities and functions 	would 	include:	 	
a) 	Lead	 the development of 	national 	environmental risk management goal	s and 	a 	
national environmental risk 	strategy	. Guide their implementation.	 	
b) 	Undertake national and regional environmental risk assessment	s and 	horizon 	
scanning to identify emerging risks	, drawing on 	a wide network of researchers in 	
many domains of environmental	 quality	, ecosystem 	integrity	, and public health	. 	
c) 	Analyze risks and decide on priority environmental risks at the national and 
regional level	s related to policies, planning	, and major investment	s. Assess	 benefits 	
and	 cost	s of policy options	, identify opportunities to reduce multiple risks, 	and 	help 	
resolve 	tradeoffs 	among risks and 	between soci	oeconomic development	 goals	 and 	
environmental risks.	 	
d) 	Assess the adequacy of government risk management policies at every level	, with 	
a view to learning and improvement over time.	 	
e) 	Identify responsibilities for risk management and 	oversee	 actions taken to manage	 	
risks by responsible g	overnment agencies	. P	rovide 	support to 	science	-based 	
decision making for environmental risk management	, and 	oversee policy impact 	
assessments	.

42 	
f) 	Initiate and monitor effective risk communication and engagement processes and 
ensure that the results of risk 	perception studies are integrated in	to risk 	
management and communication programs	. 	
4.1.	2 Establish 	a 	Comprehensive 	Environmental 	Risk	-based 	Decision	-making 	
System	 	
(1) Establish 	an 	environmental risk assessment and prevention system for national 	
macro	-strateg	ies	 for China’s national modern	ization process	 	
Carry out short	-term, m	edium	-term and long	-term environmental risk assessment	s for 	
national macro	-strategies such as 	the 	building 	of 	an overall well	-off society, new	-type 	
urbanization, integrated development of 	the 	Jing	-Jin	-Ji area, 	the 	Belt and Road initiative, 	
and 	the 	Yangtze River Delta economic zone, and develop effective environmental risk 	
prevention roadmaps	 for each macro	-strateg	y. 	
(2) Incorporate environmental risk assessment and management into 	the 	decision	-	
making systems of governments at all levels	 	
Incorporate environmental risk assessment and risk management requirements into 
government decisions	 ─ 	at every level of policy, 	planning	, and implementation	 ─ 	that 	
have a potential impact on environmental quality, ecosystem integrity	, or human health	, 	
and 	for 	the development of environmental standards	. Establish 	a comprehensive	 	
planning system and	 assessment system 	for 	decision	 making	 of 	major polic	ies and plan	s. 	
This will contribute to the government’s efforts to deepen reform and streamline 
regulatory measure	s. Specifically:	 	
a) 	Apply strategic environmental	 assessment 	(SEA)	 to incorporat	e environmental risks 	
into	 policies	, plan	s, and major 	infrastructure 	projects	 at all levels. 	Apply risk	-based 	
SEA	 strategic 	environmental assessment	, incorporating	 cost effectiveness and benefits 	
consideration	s, during the 	formulation 	of all national and sectoral polic	ies	 and plan	s, 	
including 	for	 energy, industry, agriculture, transportation, and regional development	, 	
and during feasibility assessment of 	major 	infrastructure 	projects. 	Pay close attention 	
to vulnerable people 	who 	may be affected by the implementation of 	such	 polic	ies	 and 	
plan	s. Incorporate environmental risk assessment and 	philosophy of environmental risk 	
management	 into the development of environmental standards.	 	
b) Promote 	Multi	ple	-in-One spatial plan	s, integrating	 economic and social development 	
plan	s, urban and rural plan	s, land use plan	s, and 	ecological protection plan	s into on	e 	
plan	. Apply environmental risk assessment to evaluate environmental risks, 	including 	
costs and benefits	 comprehensively	 in 	Multiple	-in-One	 spatial plan	s to 	identi	fy priority 	
zones and risks	, and draw	 ecological 	protection 	red 	line	s. Establish a system to ensure 	
synergies	 across multiple assessment	 processes including 	environmental risk 	
assessment, environmental impact assessment, 	and 	social stability risk	 assessment.	 	
(3) Incorporate 	Climate Change into 	Environmental Risk Decision Making 	 	
Conduct periodic assessments of climate change	-related environmental risks, 	
undertaken by third	-party organizations under the guidance of the National 	
Environmental Risk Board in cooperation with the 	National C	limate Strategy Centre

43 	
(NCSC), 	and involving extensive social participation. These assessments will inform 	
decisions on environmental risk management.	 	
4.1.	3 Rearrange 	Environmental 	Risk	-based	 Institution	s 	
(1) 	Establish 	a management structure 	based on environmental elements	 	
Support the transformation of 	the department structure	 of	 MEP 	to produce a coherent 	
system for environmental risk management	, with cl	ear powers and responsibilities. 	
Therefore, replace the current Departments of Pollution 	Control and Total Emission 	
Control with	 new Department	s of Air Pollution Control, Water Pollution Control	, and 	
Soil Pollution Control. Adjust the function	s of 	the 	Department of Ecological Protection 	
to include	 protection of ecosystem functions, 	nature 	reserve management	, and 	
biodiversity protection. 	It will be necessary to build in specific coordination 	
mechanisms across the new departments to avoid previous problems of fragmentation 
and to ensure that cross	-media shift	s in environmental risks 	do 	not oc	cur.	 	
In addition, it must be recognized that	 much of t	he 	work for effective environmental 	
risk management must still be done by other 	ministries, other levels of government, and 	
enterprises. The r	ole of MEP thus includes ensuring	 that a robust regulatory a	nd policy 	
framework is in place which fully integrates environmental risk management	, and 	
applies strong	 enforcement to ensure the prevention and 	reduction	 of environmental 	
risks.	 	
(2) Establish Chemical and Environmental Emergency Response Cent	res 	
Reform the management system 	for	 dangerous chemicals which 	currently 	involves 	
multiple departments. Clarify the main body of regulations	. Incorporat	e chemicals 	
management into environment	al emergency response systems	 and s	trengthen 	the	ir 	
management of haza	rdous chemicals	. 	
(3) Strengthen vertical connections of environmental departments	 	
Build strong 	vertical connections from MEP to 	provincial and 	local environmental 	
departments	 that will	 incorporat	e a consistent approach to environmental risk 	
assessment and management.	 Increase the decision	-making 	power of higher level 	
environmental departments 	for	 cadre management	, including appointment and 	
dismissal	. Boost the 	performance management of officials	 in lower	 level environmental 	
departments.	 Ensure 	the 	relative	 independence between	 local environmental protection 	
department	s and local government	s to avoid 	interference in 	environmental 	supervision	 	
and 	decision	 making	 by local governments.	 	
(4) Strengthen 	regional Environmental Supervision Centr	es 	
Clarify the role of regional Environmental Supervision Centr	es through legislation, and 	
clarify the	ir mandate 	for 	supervision as well as 	their 	responsibilities and obligations	. 	
This	 effort 	should be 	undertaken 	wit	h oversight 	by 	the National Environmental Risk 	
Board. Increase investment 	in staffing	 and equipment	. Convert public institutes to 	
government units when appropriate.

44 	
4.2 ESTABLISH ENVIRONMENTAL RISK MANAGEMENT GOALS AND 	
STRATEGY	 	
4.2.	1 Set Environmental 	Risk Management Target	s 	
The 	overall 	goal	 of environmental risk 	manag	emen	t is 	to prevent or reduce 	
environmental risk	s in order	 to secure 	human health, environmental quality, the 	
functioning and integrity of ecosystems and national security	, increase social	 well	-	
being, and make risk levels compatible with public perception of acceptable levels.	 	
(1) 	Set	 comprehensive 	national 	environmental risk reduction targets 	for priority 	
environmental risks	. These targets should 	be 	developed by the National 	Environmental	 	
Risk Board	, based on the results of a national environmental risk assessment and 	the 	
setting of 	priorit	ies it undertakes. Risk targets need to 	factor in the 	costs 	and benefits 	of 	
risk control, 	the feasibility of applying risk control technologies	, and public perception 	
of risks. 	 	
(2) 	Require 	ea	ch province, region and city 	to set	 environmental 	risk targets	. These 	
are to be set	 according to regional soci	oeconomic development conditions	 and risk 	
types	 relevant to each region	, based on the national risk targets and using methods 	
developed by the National 	Environmental	 Risk Board	. Acceptable environmental risk 	
levels differ for different types of risks and for different soci	oeconomic development 	
levels in regions and for differ	ent periods. International experience shows there is no 	
one universally acceptable risk level. Examples of risk targets are shown in 	Annex	 5. 	
(3) 	Require provinces	, cities	, and 	regions to prepare a roadmap to determine the pace 	
and path to meet the 	environmental risk 	target	s. These are to be	 based on 	priority 	
regional environmental risks, environmental conditions, econ	omic and social 	
conditions, 	regional development strategy, 	and the need to	 maintain public confidence. 	 	
4.2.	2 Establish 	and Implement a Comprehensive National Environmental Risk 	
Management Strategy	 	
Apply the principles of	 "whole process management" 	and "priority management” 	to 	
establish	 and 	implement	 a comprehensive 	environment	al risk management system in 	
China	. The goal is 	to transform 	the current reactive approach	 of environmental 	
management	, with 	its 	focus on pollution control	, to a proactive environmental risk 	
prevention and reduction mode.	 	
It is necessary to establish 	priorities 	for 	environmental risks and identify the 	
management urgency for 	different	 risks, so as to 	achieve the greatest environmental and 	
social benefits with	 limit	ed	 management resources	. 	
(1) 	Conduct a full, comprehensive national 	risk 	assessment	 and ranking	 exercise 	to 	
set national priorities	. Priorities are to be set	 for 	each of 	the 	three categories of 	
environmental 	risks	 ─	 sudden accident risks	, c	umulative threshold event risks	, and 	
long	-term chronic risks	. Since	 environmental risk priorities and goals will change with 	
the 	progress of soci	oeconomic development, 	this national 	risk 	assessment needs to be 	
conduct	ed	 periodically	.

45 	
(2) 	Establish 	and apply 	a risk chain	-based 	environmental risk management system	. 	
(Figure 1	-1 shows the risk chain)	. This is to be	 based on the assessment results	, 	
emphasizing risk avoidance and prevention, and risk response, mitigation, 
compensation	, and remediation where necessary, to reduce overall risks and yield 	
public 	health, env	ironmental quality	, and ecosystem benefits that justify the costs.	 	
Based on the results of this study, we propose a preliminary environmental risk 
management strategy roadmap	 (Table 4	-1). Further in	-depth research and assessment is 	
required to identify and 	establish 	the detailed roadmap 	for	 future environmental risk	 	
management	 in China.	 	
Table	 4-1 Preliminary 	roadmap for environmental risk management strategy in 	
China	 	
Year	 	Strategic Road	map	 	
Management	 System	 	Risk	 Level	 	
2020	 	
�� 	Environmental risk prevention and 
reduction is incorporated into the 
national macro strategy 	and into sector 	
policies, spatial plans	, and infrastructure 	
development 	decision making	 	
�� 	"Whole process management" and 
"priority management" based 
environmental risk management system 
is partially 	established	 	
�� 	A number of priority risks 	are	 in 	
progress to be reduced, for example 
PM	2.5 	
2025	-2030	 	
�� 	Environmental risk management system 
is transfor	med to 	the 	proactive mode to 	
prevent	 and reduce 	all categories of 	
environmental 	risks	 	
�� 	Environmental risk management system 
is fully implemented	 based on	 “whole 	
process management” and “priority 
management”	 	
�� 	A number of risks	 (e.g., 	
environmental risks due 	to law 	
violations, eutrophication	, heavy 	
metals in water and soil	) are	 	
successfully	 controlled	 	
�� 	Overall environmental risk is 
reduced with improved ecological 
and public health, and is increasingly 
aligned with public risk perception	 	
2040	-2050	 	
�� 	Evaluate and adjust the 	environmental	 	
risk management system to 	fit 	evolving 	
conditions and needs	 	
�� 	Some environmental risks 	will take 	
longer	 into	 this stage	 to 	be 	manage	d 	
successfully	, such as 	those related to 	
climate change	 	
�� 	Overall environmental risk is 
controlled at low level	s and in line 	
with public risk perception, and 
secures 	high levels of environmental 	
quality, and 	ecological and public 	
health

46 	
4.3	 ESTABLISH 	AND IMPROVE THE SYSTEM OF 	ENABLING MEASURES 	
FOR ENVIRONMENTAL MANAGE	MENT	 	
4.3.	1 	Strengthen 	and Complete	 Legislation and 	Strengthen the 	Judiciary for 	
Environmental 	Risk 	M	anagement	 	
(1) Complete 	the system of 	environmental risk management laws and regulations	 	
With the goal of 	transforming the current reactive	 environmental management	 approach 	
to a proactive environmental risk prevention and reduction mode,	 and applying	 whole 	
process 	management, 	it is necessary to 	improve laws and regulations for environmental 	
protection. 	 	
First, fill the 	gaps in law	 for	 environmental risk	 management	. 	
a) 	Develop 	a new 	Environmental Liability Law	. This	 law would have 	provisions for 	
ecologi	cal damage compensation	 and 	restora	tion, causality identification	, public 	
interest litigation, environmental damage evaluation, liability insurance	 and broader 	
financial assurance	, as well as system	s for funding	 and	 dispute resolution.	 	
b) 	Develop environmental management laws for soils and contaminated site	s. Issue 	
the 	Soil 	Environmental Protection	 Law 	as soon as possible	 and develop 	supporting laws 	
and 	regulations	 for 	contaminated 	sites 	management.	 Soil environmental legislation 	
should 	pay	 more attention to the protection 	of clean soil, especially farmland, and the 	
management and control 	of contaminated sites	. 	
Second, environmental risk	-related	 provisions	 in existing laws and regulations 	are not 	
specific 	and clear 	enough	 and their operability is low.	 Thus there 	is a 	need to r	evise 	
existing laws 	and regulations 	to incorporate and make environmental risk control 	
provisions more concrete.	 	
c) 	Develop a 	Dangerous Chemicals Safety and Environmental Risk Law	 that applies 	
to all dangerous chemicals	. This law would be 	based on the existing 	Hazardous 	
Chemical Safety Management Regulation	 and focus	ed	 on	 implement	ing	 life	-cycle risk 	
management for chem	icals, 	including comprehensive risk assessment of new chemicals, 	
provisions for chemicals production, 	handling, 	transport, storage, use	, and waste 	
management, as well as disclosure 	of chemicals use, transportation	, and storage	 by 	
industry and government 	ministries and agencies	 	at all levels	. 	Strengthen 	
comprehensive	 supervision	 and regulation 	of 	priority pollutants	 in the 	process of 	
industrial production	. 	
d) 	Revise 	Civil Law or Tort Liability Act	. Expand the scope of compensation for 	
personal injury 	caused by environmental pollution, clearly incorporate potential health 	
damage into compensation, clarify standa	rds for direct and indirect loss	 identification, 	
and incorporate pure economic loss into property damage compensation	, as appropriate. 	 	
Third, 	conduct 	retrospective assessments for 	all 	relevant 	laws 	on a periodic (5 or 10 	
year	) basis	 and revise or amend relevant laws according 	to results of the	se	 assessments 	
and 	changing 	social	, economic	, and environmental	 risk 	conditions	.

47 	
(2) Promote 	and strengthen the 	environmental judiciary	 	
Although the e	nvironmental judiciary	 system in China is still in its early stages, the 	
system 	is important	 to ensure that	 environmental protection laws and reg	ulations 	are 	
enforced. Put in place 	measures to promote the 	environmental judiciary in China, 	
including 	the 	training	 of	 professional 	judiciary	 human resources and promoting public 	
consciousness 	about	 environmental rights	. 	
4.3.2 	Enable 	Environmental 	Risk 	Information 	Integration and 	Sharing	 	
Vertical and 	horizontal	 fragmentation of 	environmental risk information	, including its 	
storage and management	, has resulted in 	data redundancy and conflict	s. Taking the 	lead 	
from the 	State Council	’s 2015 	Construction Plan for 	an 	Eco	-environmental	 Monitoring	 	
Network	, integrate environmental risk information which is distributed across multiple 	
government 	departments into 	a national unified envi	ronmental information platform	, or 	
data centr	e, and establish 	a specific 	subdivision for environmental risk 	information	. 	
This subdivision will 	includ	e information on 	risk 	attribute	s and spatial information 	on	 	
environmental risk sources and surrounding sensitive receptors, monitoring and 
management information	 on risk sources	, and relevant policies, laws	, and 	regulations	. 	
Develop specific agreements and protocols for 	sharing 	environmental risk 	information	, 	
both 	horizontally	 and vertically	 across 	environmental protection	 departments and 	
between MEP and	 other	 government 	ministries	. 	
Support extensive research on 	environmental exposure and dose response functions 	
based on ecotoxicology, human health risk, and environmental epidemiology to fill data 
gaps	. The	se data can be incorporated into the 	unified environmental risk information 	
database	. 	
4.3.	3 Apply 	Financial	 and 	Economic	 Instruments to 	Prevent 	and 	M	anage 	
Environmental 	Risks	 	
Higher quality	 environmental financial instrument	s are	 required for environmental risk 	
management	. Establish 	an 	enterprise financial 	security system	, based on environmental 	
risk, 	 for 	sudden 	accident	, cumulative	 event	, and chronic	 environmental risks	, including 	
liability insurance for industries and enterprises	, an 	environmental risk deposit system 	
for high	-risk industries	, and 	special funds for 	legacy	 contaminated site 	clean	-up	 and 	
remediation.	 Economic measures such as market based regulation also should be used 	
to prevent and reduce environmental risks.	 	
(1) 	Improve 	the 	environmental liability 	and financial as	surance system	 	
Clarify the role of	 environmental liability insurance	 and other financial assurance 	
instruments 	from	 the	 legal perspective, 	and 	apply mandatory 	liability insurance	 and	/or	 	
other financial assurance 	for high	-risk industrial sectors. 	Based on sector characteristics, 	
develop guidelines for enterprise environmental risk assessment, 	damage verification	, 	
and 	determination of 	compensation	 methodology	. This will 	provide technical support 	
for 	improvement 	and implementation of 	an 	environmental risk liability 	insurance	 	
system	 and 	assist in the 	determination of premium rates	.

48 	
(2) 	Establish and 	optimize	 special funds for 	environmental risk control	 	
Establish 	an 	environmental risk 	deposit	 system	 for high	-risk industries	. Enterprises	 with 	
high environmental risks	 would 	pay corresponding deposits to environmental 	ministries 	
and bureaus, 	according	 to their risk 	classifications. This	 will enable 	environmental 	
agencies 	to 	pay 	damage compensation and remediation	 costs	 using the deposits 	when 	
environment	al risk events happen.	 These 	ministries and bureaus 	can hold 	accountable	 	
the 	responsible	 enterprises 	after the events, so as to protect the environmental rights of 	
the people surrounding the 	enterprises	. 	
Establish special funds for 	contaminated	 site 	clean	-up	 and remediation.	 With 	the 	
progress of urbanization, 	some contaminated sites in 	urban	 areas may be re	-developed. 	
Remediation management of contaminated sites is urgently required.	 How	ever, 	
remediation 	costs 	are 	high, which is 	a 	major 	barrier 	for 	the redevelop	ment	 of 	
contami	nated sites.	 Further, f	or s	ome contaminated sites	, the responsible enterprises 	
cannot be found or 	have become	 bankrupt	, so that 	funds for site remediation cannot be 	
guaranteed.	 	
4.3.	4 Establish a collaborative multi	-department environmental emergency 	response 	
system with practical emergency response plan	s as 	a core requirement	 	
(1)	 Develop relevant policies and measures to improve	 the 	effectiveness	 of 	
environmental emergency response plans at all levels	. The National 	Environmental 	
Risk Board	, in collaboration with professional organization	s, should be	 responsible 	for	 	
develop	ing	 guidelines	 for 	these 	plan	s and 	for 	supporting policies to	 ensure	 effective 	
response plan 	development and 	training 	exercises	. 	
(2) 	Establish 	strong 	environmental 	emergency response capacit	ies	. Establish j	oint 	
emergency response mechanism	s with clear power	s and responsibilit	ies	 and 	
requirements for 	information sharing	, with emergency response plans as the core	. This 	
would	 	involv	e 	government departments 	responsible for 	safety supervision	, 	
transportation, environmental protection, and 	public security	, as well as enterprises	. 	
Optimize the allocation of regional environmental emergency resources. 	 	
4.3.	5 Establish 	a Responsib	ility	 System for 	Industries and 	Enterprises	 	
Establishing 	corporate environmental risk responsibility 	needs to 	start from the 	
relationship among government, 	the 	public	, and enterprises, 	to motivate enterprise	s 	
under internal	 and external	 pressure to establish and improve their	 acceptance o	f 	
responsibilities	 for 	environmental risk	s. Government has a role in creating the right 	
conditions	, through a combination of law and regulation	, with enforcement and 	
incentives to industry to act responsibly.	 	
(1) Drive 	and support 	industry sectors to be 	responsible for adopting environmental 	
risk management practices	. Clarify the response and remediation responsibilities of 	
industries and enterprises for	 accidental and	 legacy risks	, specify in law and regulation	 	
environmental risk information disclosure obligation	s, and provide regulatory 	
recognition for adoption of leading practices by enterprises. 	 	
Apply 	a series of incentive measures in the fields of investment, 	green 	credit, tax	es and 	
fees	, land, market acces	s, government procurement	, and tradable quotas	 to create an

49 	
environment that encourage	s leading enterprises to establish 	their 	environmental risk 	
responsibility system.	 Provide training	 in EHS practice for enterprises	, and d	evelop 	
measures to 	spur 	enterpri	ses to establish their EHS systems.	 	
Focus on sectors with critical environmental risks	. These would include	 the chemical 	
industries	. T	hrough their industry 	groups	 such as the 	Association of International 	
Chemical Manufacturers (AICM)	, e	ncourage them	 to broaden in China the application 	
of the successful international Responsible Care	® Program. Similarly	, engage 	the China 	
Mining Association to address environmental risks.	 	
(2) 	Develop and implement a program	 for environmental risk management	 	
improvement	 in state enterprises	. Require state enterprises to raise the level of 	
environmental risk management to the international standards applied by foreign 
companies	, and provide incentives and support	 for	 them to become national leaders	. 	
Led by MEP 	and 	working with 	each sector m	inistry, develop	 environmental risk 	
assess	ment 	and	 EHS training	 for state enterprises, based on priority risks identified by 	
the National 	Environmental 	Risk Board.	 Promote 	a third	-party service market	 mak	ing	 	
full 	use of professional organizations in corporate environmental risk management, and 	
provide professional services to 	small and medium enterprises	 in this field.	 	
(3) Put in place rules for 	mandatory 	environmental risk disclosure in 	the 	financial 	
reporting 	requirements of the China Securities Regulatory Commission	. Through 	
mandatory information disclosure, environmental risk management become	s a major 	
factor that can affect 	enterprise 	financing 	and 	stimulate	 stock	 exchange 	list	ed	 	
enterprises 	to 	conscious	ly and active	ly implement	 environmental risk management 	
practices.	 	
4.4 	ESTABLISH 	AN 	ENVIRONMENTAL RISK COMMUNICATION AND 	
ENGAGEMENT SYSTEM	 	
4.4.	1 Develop a transparent and effective environmental risk communication system	 	
The d	iversity and complexity of environmental risks requires more 	effective 	and 	
responsive 	communication, 	cooperation	, and negotiation	 among	 government agencies 	
and 	multiple stakeholders	. Poorly informed public risk perceptions may result in 	the 	
exaggeration 	or 	the 	attenuation	 of the actual risks	, or 	the 	neglect of other risks	. It may 	
also result in inappropriate 	emergency	 response to 	risk	 events. 	 	
(1)	 Establish an environmental risk data sharing mechanism across ministries, and 	
with provincial and local envir	onmental bureaus	. This can be b	ased on the 	Plan for 	
an 	Eco	-environmental	 Monitoring	 Network	. Establish an accessible 	mechanism for 	
public disclosure of 	risk information	, to be implemented by government ministries and 	
provincial and local environmental 	bureaus	. The mechanism will include	 requirements 	
for disclosure of 	multi	-source risk information	, including risk sources	 and location, 	
regular environmental monitoring results for the sources, risk assessments, 
environmental emergency response plans	, and 	information on 	public perception of risk. 	
Such information provides a basis for the building of an efficient and orderly 
environment risk communication and public engagement system	. 	
(2) Develop a	 multi	-dimensional	, transparent environmental risk 	communication 	
and engagement system	. This should	 involv	e multiple stakeholders including

50 	
government 	ministries	, enterprises, 	representatives of citizens and communities, 	media, 	
and social organizations	. The system should	 us	e various measures such as inform	ation 	
transfer	, round	-table conference	s, and community engagement.	 	
Establish	 mechanisms for risk knowledge transfer to and from the public	, including	 on	 	
specific	 risk reduction strategies and hazard chain information, so that 	government 	
ministries and 	bureaus	 better understand	 public preferences and 	the public has a 	better	 	
perception of environmental risks. 	 	
It is also essential to familiarize citizens and communities with risks that they will face 
in everyday life. They need to know how to behave in em	ergencies and gain knowledge 	
about self	-rescue, evacuation	, and strategies for avoiding damage after an 	
environmental risk incident. 	Effective communication lowers public vulnerability to 	
risk events, especially for 	vulnerable	 people and	 the 	most exposed 	segments	 of the 	
population.	 	
4.4.	2 Establish 	Effective 	Environmental 	Risk 	Engagement 	Program	s 	
Environmental	 risk	 management is not only	 a matter 	for	 government departments	 and 	
enterprises, but also 	an opportunity to	 involve the relevant stakeholders such as affected 	
communities	, social organizations, 	scientific research institutions	, and the broa	der 	
public	. Establish 	an environmental risk management and e	mergency response	 system	 	
involving all 	relevant 	stakeholders	 and	 specify	 their roles in environmental risk 	
management 	including	 emergency response	. It is important to 	value their 	contribut	ion	 	
to 	environmental risk management	, including 	emergency response	, with their special 	
knowledge, their familiarity with the region or 	locale, and the 	specific mitigation or 	
adaptation skills	 they posses	s. 	
Develop community and public engagement models for dialogue and feedback from 
affected 	communities	. Involve	 relevant stakeholders to co	-design environmental risk 	
management policies	 and 	include	 the feedback from stakeholders	 in policy	 and 	
planning	 design	. Promote	 public participation in policy and regional plan development, 	
and in the conduct of policy	 and 	plan	-level SE	A and project EIAs	.

51 
 
 
 
 
 
 
 	
 	
 
China Council for International Cooperation on Environment and 	
Development (CCICED)	 	
 
 
 
 	
 	
 	
Special Policy Study	 Report	 	
 	
Eco	-environmental Risk Management	 	
Annex	 	
 
 
 
 
 
 
 
 
 	
CCICED 2014 Annual General Meeting	 	
November 9	-11, 2015

52	 	
ANNEX	 1. 	Description of Three Categories	 of Environmental Risks	 	
Category 1:	 Sudden pollution accident risk. 	This type of environmental risk event 	
occurs mainly due to the natural or human	-caused fire, explosion, or leakage of 	
hazardous chemicals from production, storage, transportation, and wast	e 	treatment 	
facilities	. A quantity of pollutants is released suddenly and poses acute effects on 	
ecosystems, environmental quality, and human health.	 	
Category 	2: Cumulative threshold event risk. 	This type of risk event happens mainly 	
due to	 human	-caused lo	ng	-term and chronic discharge of pollutants. The acute 	
consequence occur	s when exposure accumulates to certain levels exceeding a threshold 	
or tipping point	. For example, the Taihu Lake blue algal bloom event in 2007 was the 	
result of long	-term discharge o	f nitrogen and phosphorus	 together with the appropriate 	
weather conditions s	uitable for algae growth	. Many episodes of elevated blood lead 	
levels in children 	that have occurred in recent years were the result of long	-term 	
discharge of heavy metals which ac	cumulated to toxic levels. Acute air pollution 	
episodes are another example.	 	
Category 	3: Long	-term chronic environmental risk. 	This type of risk poses chronic 	
adverse effects	 due to human	-caused 	long	-term	 discharge of pollutants or persistent 	
pollution in environmental media, for example: chronic ecosystem effects, human 
health effects from PM	2.5	 pollution, contaminated sites, new chemicals and emerging 	
pollutants, radiation sources and nuclear wastes, as 	well as long	-term e	cological 	
degradation 	due to	 infrastructure or 	regional development	. Some pollutants	 with 	
climate change effects, such as 	short lived climate pollutants	 (short	-lived climate	-	
forcing pollutants	, that is, 	black carbon and tropospheric 	ozon	e), have both adverse 	
health effects and a greenhouse effect. 	 	
It should be noted that Categories 2 and 3 may share the same risk sources. For example, 
exposure to contaminated sites may not only 	cause unnoticed chronic	 health effects	, but 	
also may cause 	visible	 and acute events	 when contamination reaches a threshold. 	
Another example is that PM	2.5	 pollution not only causes chronic health risks, but also 	
may cause heavy pollution 	episodes	 when weather conditions limit 	its diffusion.	 	
In Figure 1	-3, Category 1	 sudden pollution accidents may involve persistent pollutants. 	
After the emergency response to the accident, 	persistent pollutant	 residues may remain 	
in environmental media for a long time and thus form contaminated sites or sediments. 
In that case, environmental risk before pollution accidents can be classified to Category 
1. After emergency disposal, contaminated sites or sediment	s would become new risk 	
sources and thus can be classified as Category 2 or 3. For example, 	nitrobenzene	 in the 	
2005 Songhua River pollution accident, crude oil in the 2010 Dalian oil pipeline 
explosion, and cadmium in the 2012 Longjiang River cadmium poll	ution accident, all 	
may lead to 	residues	 in sediments and would pose long	-term ecological and health risks.

53	 	
ANNEX	 2. Problems of Current Environmental Emergency Responses	 	
Th	is study selected the 50 typical pollution incident cases from 	Typical 	Environmental 	
Accident Cases (Part I)	 (MEP Emergency Response Lead Group Office, 2011)	 to 	
analyse the main reasons for 	the 	ineffectiveness of environmental emergency response	, 	
as shown in 	Annex Table 2	-1. 	
Annex Table 2	-1 	
The main reasons for 	ineffectiveness of environmental emergency response from 	
50 cases	 	
Reasons	 	Proportion	 	
Emergency response monitoring was not reasonable with incomplete or 	
unreasonable monitoring indicators and lack of post supervisory monitoring.	 	48%	 	
Insufficient 	cross	-department and cross	-region coordination, with information 	
sharing and joint	 action to be strengthened.	 	40%	 	
Lack of emergency response and protection equipment, resulting in ineffective 	
pollution reduction and health threat to emergency response sta	ff.	 	28%	 	
Did not disclose relevant information at the early stage of incidents, causing 	
public panic and influencing social stability.	 	28%	 	
Lack of effective emergency response plan and scientific decision making, 
improper emergency response measures at th	e early stage of incidents which 	
contributed to inadequate pollution control and even cause	d secondary 	
pollution.	 	
26%	 	
Did not have scientific and timely warning on air and water environment	, a 	
circumstance	 which was unable to provide support to decision making.	 	22%	 	
Limited emergency response monitoring capacity and shortage of staff.	 	20%

54	 	
ANNEX 3. Current Environmental Risk Levels in China	 	
For this study seven representative indicators from seven 	environmental risks were 	
selected to characterize the c	urrent 	environmental 	risk 	levels in China	, including 	
accidental pollution events; soil, air, and water pollution; climate change; economic 
loss; and public demands (Annex Table 3	-1). 	Meanwhile, based on the consideration of 	
current levels of the indicators, 	Annex Table 3	-1 suggests 	a preliminary 	comparison 	of 	
each 	current 	indicator 	level with 	three risk levels	 - low, medium, and high 	- sketching 	
a rough range of possibilities.	 For exam	ple, for the indicator of “annual 	environmental 	
risk accidents	,” considering that the pollution accident frequency 	in China 	before 2005 	
was relatively high (over 1000 events each year), 1000 is identified as the high level 
and reflect	s the effectiveness of	 environmental risk control 	since	 2005.	 	
According to 	Global Burden of Death (GBD) 	2010	 study 	data	41, the 	premature death 	
rate attributable to PM	2.5	 is 	0.6×10	-4 in Australia, which is one of the least 	PM	2.5 	
polluted countri	es in the world (where the population weighted annual 	PM	2.5 	
concentration is 2.3 μg/m	3). Thus 	0.5×10	-4 is set as	 the	 low risk level. And 	10	×	10	-4 is 	
set as	 the	 high risk level, which is near the current level of China	. 	
For the 	environmental complaint	 rate	, considering 	that 	it continues 	to increase	 since 	the 	
1990s, this study suggests 	that	 levels in 	the 	early 1990s 	were at	 a low	 level 	and 1	‰	 is 	
the high public demand level, which is near the current situation.	 Risk levels of other 	
indicators are set based o	n their current status and relevant demands for environmental 	
management in China.	 	
Annex Table 3	-1 C	urrent environmental risk levels in China	 	
Indicators	 	Low	 	M	edium	 	High	 	Current	 	
Annual environmental risk 	
accidents	 a 	50	 	100	 	1000	 	452	 	
Proportion of 	contaminated soils	 	
(%)	 b 	5 	10	 	20	 	16.1	 	
Premature death rate attributable 	
to PM	2.5	 c 	0.5	×	10	-4 	5×	10	-4 	10	×	10	-4 	9×10	-4 	
Proportion of inferior V water	 d 	1 	5 	10	 	9.2	 	
Environmental risks due to 	
climate change	 e 	NA	 	NA	 	NA	 	Medium	 	
Proportion of environmental 
losses	 compared to GDP	 % f 	0.5	 	2 	6 	6 	
Environmental complaint	 rate 	
(‰	) g 	0.1	 	0.5	 	1 	0.89	 	
a 	Current level: From 	China Environment	al Statistical Yearbook	 (2014)	. 	
b 	Current	 level: From	 the first national soil pollution investigation 	results released	 by 	MEP 	
and	 Ministry of Land and Resources in 2014.	 	
c 	Current	 level: Calculated from 	GBD	 2010 and Chinese population.	 	
d 	Current	 level: From	 Environment Quality Bulletin (2014).	 	
e 	Including health risks of complex air pollution	 and biodiversity losses	 due to climate 	
chan	ge, secondary environmental pollution accidents	 due to climate change	-related natural 	
 	 	 	
41 http://vizhub.healthdata.org/irank/heat.php

55	 	
disasters	 such as coastal and river flooding and extreme weather events	, etc.	 Based on the 	
current trends of global warming, environmental risks due to climate change 	will be more 	
serious in the future. Thus the current risk level is set to medium	. A quantitative analysis 	
has not yet been undertaken	 by this study.	 	
f 	Current	 level: From the report of 	Impacts of Environmental Protection on 	Economic	 under 	
New Normal Situation	 issued by MEP in 2015. 	http://news.xinhuanet.com/fortune/2015	-	
09/09/c_1116513933.htm	。	 	
g 	Current	 level: Calculated using data from	 China Environment	al Yearbook	 (2014) 	and 	
China 	population.	 	
 
The 	“e	nvironmental risk rose	” (Figure 1	-9) is based on 	Annex Table 3	-1. The figure 	
intuitively 	demonstrates examples of 	multiple	 environmental risks and the associated 	
levels. The	 environmental risk rose can be applied to demonstrate the risk management 	
goals in the future.	 Note that 	this figure presents the result of only a preliminary analysis, 	
which cannot completely characterize risk levels for all kinds of environmental risks. 
The	 risk examples are preliminary and the risk levels represent semi	-quantitative results. 	
The distances	 between circles in the rose diagram are not to scale.	 The points around a 	
given circle do not necessarily represent equal levels of risk or seriousness. For example, 
around the outer	-most circle, 10 x 10	-4 risk from PM	2.5 air pollution corresponds to 	
rough	ly 1.3 million deaths per year in China, whereas 10% inferior V water or 1000 	
environmental incidents may not be associated with such high mortality levels. And 
movements along the radius lines of the rose, from the outer circle toward the center	, 	
do not n	ecessarily represent equal or proportionate reductions in risk.

56	 	
ANNEX 4. Prospects for Driving Forces of Environmental Risks in China	 	
4.1 Driving Forces of Environmental Risk	 	
Driving Forces of Environmental Risk Levels	 	
Based on the model of the 	environmental risk chain (Figure 1	-2), social needs are the 	
origins of the formation and existence of environmental risk sources. Environmental 
risk sources are formed during the process of soci	oeconomic activities	. Thus 	
environmental risk pressure factors	 can be characterized by indicators which can reflect 	
soci	oeconomic activities	, such as GDP and industrialization.	 And 	along the whole 	
process of the environmental risk chain, causes of environmental risk events may exist 
in any risk chain node with poor m	anagement. Thus the level of environmental risk	 	
management applied is also an important factor which can influence risk levels. In 
addition, technological progress can also benefit environmental risk reduction. 	 	
Driving Forces of Public Environmental Risk 	Perceptions	 	
The public response to environmental risk based on people’s own subjective 
perceptions may vary significantly 	with differing 	socioeconomic status and education 	
levels, which will influence judgement and acceptable risk level. A total of 3550 
samples from 16 cities in Jiangsu, Anhui	, and Yunnan 	provinces were surveyed for 	
determining the desired level of acceptable	 risk	 42	. The	 analysis concluded that 	
economic development level and education level are the two most important factors 
influencing 	ac	ceptable risk level	 (Annex 	Figure 	4-1). Acceptable risk level decreases 	
with the increase of per capita GDP (or national income) and education levels. 	 	
In addition, the 	emergence of new media such as the internet facilitates faster 	
dissemination of information. Information dissemination through new media may result 
in exaggeration of risk information which may magnify the actual risks and lead to 
larger gaps between publi	c perception levels and objective risk levels. For example, 	
several 	para	-xylene (PX) projects	 have had mass protest incidents in recent years. In 	
some cases, rumours may be disseminated. For example, the rumour of explosions of 
chemical plants in Xiangshui	 county, Jiangsu, in 2011 caused panic and the relocation 	
of tens of thousands people in nearby communities. In other cases risks are 
underestimated or poorly communicated, such as when smog was once dismissed as 
“fog” or people in some cancer villages are	 unaware of the risk they are exposed to. 	
Thus 	appropriate risk communication to	 bridge	 the gap between environmental risk 	
levels and public acceptance levels	 needs to be considered.	 	
 	 	 	
42	 Bi, J et al, 2012. R	esea	rch report of China’s 863 project of “Research on Integrated Technology 	
System of Major Environmental Pollution Accident Emergency Response”. Unpublished	.

57	 	
 	
Annex Figure 4	-1. Relationship between 	acceptable 	risk and 	per capita G	DP	 and 	
education	 (The area size of the circle represents the public Maximum Acceptable 	
Risk Level	, i.e., MARL	) 	
 
Studies have shown that 	risk cognition and public perceived risk loss	 have the 	
relationship shown in 	Annex Figure 4	-2. In recent years, with the increase in public 	
education levels and development of information 	dissemination	 technology, t	he public 	
has gained	 more	 knowledge about environmental risk	s than ever before. However the 	
public is still at a stage with insuffici	ent knowledge (left side of the curve peak).	 The 	
increase in risk cognition results in increasing perceived risk loss, which lower	s the risk 	
acceptance level. Without proper risk communications, the risk level will be 
exaggerated when public risk acceptanc	e level decreases to a certain level. This 	
explains why there are so many “not in my backyard” events in China in recent years. 
Thus proper environmental risk communication and engagement are needed to 
continually increase public risk cognition to ensure t	hat the public perceived risk loss 	
is in line with the science	-based risk loss (right side of the curve peak).

58	 	
 	
Annex Figure 4	-2. Relationship between risk cognition and public perceived risk 	
loss	43 	
 	
4.2 	Prospects 	for	 Driving Forces of Environmental Risk Levels and Public Risk 	
Perceptions	 	
Prospects 	for Driving Forces of Environmental Risk Levels	 	
GDP growth and industrialization. 	Using data from the	 China Statistical Yearbook	, 	
Annex Figure 4	-3 shows GDP growth and its composition in China from 1978 to 2014. 	
It can be seen that China’s economy has had a high rate of growth since the 1990s.	 With 	
the World Wide Fund for Nature	 and China’s Policy Research Center for Environment 	
and Economy, MEP iss	ued a report on 	Indicator Instrument and Empirical Study for 	
Green Economic Decision Making	 in 2015	. The results show that 	China's economic 	
growth is still dri	ven by heavy chemical industries, which	 account for more than 70% 	
of the industrial gross output 	since 2005. The gross output of heavy chemical industries 	
keeps increasing and its energy consumption has increased from about 1.5 billion tons 
of 	standard coal equivalent	 in 2001 to 3.75 billion in 2013, with significant increase in 	
air pollution risk inc	luding PM	2.5	. 	
In recent years, China’s economic growth rate has been slowing and	 it is going through 	
structural adjustment	. T	he G	DP growth rate in 2014 was 7.3% 	- down from about 10% 	
in preceding years, but still at a high level. The Economic R	esearch	 Institute of t	he 	
National 	Development and 	Reform 	Commission	 issued the interim report 	Research on 	
Development Environment, Trend, and Strategy of China during 13	th Five	-year Plan	, 	
 	 	 	
43 Bi, J et al, 2006. Regional Environmental Risk Analysis and Management, China Environmental 
Science	 Press.

59	 	
showing that the GDP growth rate during the 	13	th FYP 	period will remain at 	about 7% 	
and gross output of heavy chemical industry will also keep increasing. 	 	
In addition, to p	romote economic development, China will implement a series of 	
national development strategies such as the Belt and Road	 initiative	, integrated 	
development of 	the 	Jing	-Jin	-Ji area	 (the Beijing	-Tianjin	-Hebei “supercity”)	, and 	the 	
Yangtze River Delta economic zon	e. These will become 	new economic growth point	s. 	
The construction and operation of 	infrastructure and industrial projects	 during the 	
implementation of these strategies will pose great pressures on regional environmental 
quality and ecosystems, especially fragile ecosystems.	 	
Climate change.	 In addition to growth and industrialization,	 global warming and	 	
climate change may als	o add stresses to China’s public health and ecological challenges	. 	
Climate change can create both direct and indirect environmental risks for humans and 
ecosystems.	 For example, h	igher temperatures may exacerbate air pollution	 that may 	
pose more long	-term 	and chronic health risks	. Higher temperatures may also 	reduce 	
ecosystem resilience to environmental risks	; for example, e	xtended droughts may 	
undermine 	fragile eco	-systems. 	Sea level rise, storm surges and flooding may damage 	
coastal 	eco	-environments	 along	 waterways	. Meanwhile, the increased probability of 	
natural disasters induced by climate change may also increase the probability of 
secondary sudden pollution accidents. Global warming has been a universally accepted 
fact. Climate change in the future wil	l increase the environmental risk levels.	 	
 	
 	
Annex Figure 4	-3. GDP growth and its composition in China	 (1978	-2014	)

60	 	
Prospects 	for Driving Forces of Public Risk Perceptions	 	
During the 13	th FYP period and in the years following 	- although China will see a 	in a 	
slowing of 	economic	 growth and	 structural adjustment	 - the growth rates are still at 	
relatively high levels, and 	per capita GDP	 and 	average income level	 will keep rising. 	
According to	 the	 China Statistical Yearbook	, China’s per capita GDP in 2014 was 	
around 7500 US dollars. The 	report of 	Research on Development Environment, Trend, 	
and Strategy of China during 13	th Five Year Plan	 shows that China’s per capita GDP 	
in 2020 will be over 10,000 US dollars and reach the levels of 	moderately developed 	
countr	ies. 	 	
For the education trend, according to 	National Middle and Long	-term Education 	
Reform and Development Plan (2010	-2020)	, the population with a level of education 	
will reach 145 million in 2015 and 195 million in 2020. It can be expected that public 
dem	ands for education and the national education level will keep rising after 2020. Thus 	
the public environmental risk acceptance levels will keep decreasing as educational 
level and individual income continue to grow in the future.	 	
Overall Prospects for Envi	ronmental Risk Driving Forces in China	 	
Based on the above analysis, the prospects 	for	 driving forces of environmental risk 	
levels and public perceptions are summarized in 	Annex Table 4	-1. 	
Annex 	Table 4	-1 Prospects	 for	 Environmental Risk 	Driving Forces	 in 	China	 	
Driving forces	 	Short and Middle Term 2015	-2030	 	Long Term 2030	-	2050	 e 	
Driving forces of 	
environmental 	risk 	levels	 	
GDP	 	increase rapidly	 a 	keep increasing	 but 	more slowly	 	
Gross output of heavy chemical 	
industry	 	
increase rapidly	 b 	keep increasing	 but 	more slowly	 	
Climate	 change	 	become more serious	 	become more 	serious	 	
Environmental risk management level	 	
keep improving but 	
driven by 	environmental risk events or activities	 	
keep improving but 	
driven by 	environmental risk events or activities	 	
Environmental 
science and 	technology	 level	 	keep increasing	 	keep increasing	 	
Driving forces of 	public 	environmental 	risk 	acceptance 	levels	 	
Education	 	increase	 c 	increase	 	
National income	 	increase	 d 	increase	 	
a 	According to	 China Statistical Yearbook	, the GDP growth rate in 2014 was 7.4%. 	
The interim report of 	Research on Development Environment, Trend, and Strategy 	
of China during 13	th Five Year Plan	 by	 the Economic R	esearch	 Institute of t	he 	
National 	Development and 	Reform 	Commission	 shows that the GDP growth rate 	
during the years of the 	13	th Five Year Plan 	will remain about 7%.

61	 	
b 	According to the report of 	Indicator Instrument and Empirical Study for Green 	
Economic Decision Making	 issued by the World Wide Fund for Nature and China’s 	
Policy Research Center for Environment and Economic, MEP, heavy chemical 
industries account for more than 70% of the industrial gross output 	- a figure that 	
keeps increasing	. 	
c 	According to 	National Middle and Long	-term Education Reform and Development 	
Plan (2010	-2020)	, the population with high education level will reach 195 million 	
in 2020 	- which is 50 million more than 2015.	 	
d 	According to	 China Statistical Yearbook	, China’s per capita GDP in 2014 was 	
around 7500 US dollars. The 	report of 	Research on Development Environment, 	
Trend, and Strategy 	of China during 13	th Five Year Plan	 shows that China’s per 	
capita GDP in 2020 will be over 10000 US dollars.	 	
e 	Preliminary analysis based	 on short and middle term prospects.

62	 	
ANNEX 5. The Risk Goals	 under Various Laws and Regulations in the United 	
States and the European Union	 	
Annex 	Table 	5-1 provides the risk goals 	of various laws and regulations in the United 	
States and the European Union. These are variously expressed in quantitative, 
qualitative,	 or technology terms.	 	
Annex Table 5	-1 Risk Goals in Risk	-Based Laws and Regulations	 	
United States	 	
Risk Goal/Target	 	Domain	 	Scope/Objective	 	Law/Regulation	 	
Apply Maximum Available 
Control Technology	 	
(MACT	). If residual risk of 	
most exposed individual 
remains greater than 10	-6, 	
then more stringent 
measures must be adopted.	 	
Environment	 	Air toxics:	 	
Develop air pollutant	-based air 	
quality standards according to 
protection target. MACT is set to 
equal the best 12% of industry 
performance in each source 
cate	gory.	 	
US 	Clean Air Act	, 	
section 112	 	
Protect public health and 
welfare with an adequate 
margin of safety	 	
Environment	 	National ambient air quality 
standards (NAAQS)	 	
US 	Clean Air Act	, 	
sections 108	-109	 	
“Best technology” 
requirements, which 
explicitly or implicitly may 
include cost	-benefit 	
considerations 	 	
Environment	 	Integrity of chemical, physical 
and biological contents of 
national waters	 	
US 	Clean Water 	
Act	, sections 304, 	
316	 	
Maximum contaminant 
levels	 (MCLs) that approach 	
the level of “no observed 
adverse effect”	 	
Environment	 	Drinking water standards; 1996 
amendments authorized EPA to 
set “alternative MCLs” using 
cost	-benefit and risk	-risk tradeoff 	
analysis	 	
US 	Safe Drinking 	
Water Act	 	
Prevent 	unreasonable risk	 	Environment	 	Manage the production and 
circulation of industrial chemical 
products 	 	
US 	Toxic 	
Substance Control 
Act	 	
Food additives allowed only 
if reasonable certainty of no 
harm	 	
Food safety	 	Manage consumer health risks 
from food additives	 in processed 	
food	 	
US 	Food, Drug 	
and Cosmetic Act; 
Food Quality 
Protection Act	 	
Set standards that ensure a 
“reasonably safe and 
healthful workplace	”. 	
Regulate workplace toxic 
substances “to the extent 
feasible”	 	
Workplace 
health and 
safety	 	
OSHA must 	demon	strate some 	
“significant” risk before 
regulating	 (as clarified by 1980 	
Supreme Court 	decision). 	
“Feasible” interpreted by 1981 
Supreme Court decision as the 
maximum degree the industry 
could afford without shutting 
down.	 	
US 	Occupational 	
Safety and Health 
Act	 	
European Union	 	
Risk Goal/Target	 	Domain	 	Scope/Objective	 	Law/Regulation	 	
Best available technology 
(BAT) in different industries	 	
Environment 
– air	 	
Prevent, reduce and mitigate to 
the extent possible industrial 
pollution through establishing a 
framework	 to control industrial 	
activities	. 	
Industrial 
Emissions 
Directive

63	 	
Quality goals for Good 
Ecological Status and Good 
Chemical Status 	 	
Environment 
– chemicals + 
water	 	
Standards and measures through 
enforcing basin environmental 
quality and integrated 
management; Based on available 
scientific and technical data, 
environmental conditions in the 
various regions, and the economic 
and social development of the EU 
as a whole	 	
Water Framework 
Directive	 	
Burden of proof on 
companies	 - to demonstrate 	
how the substance they 
manufacture and market 
can be safely used. 	 	
Environment 
- chemicals	 	
Protect human health and eco	-	
environment from risk of 
chemical products, and enhance 
competitiveness of EU chemical 
industry; ECHA has marked a 
numbe	r of Substances of Very 	
High Concern (SVHC) as having 
particularly high environmental 
risk	 	
REACH Directive 
- Registration, 
Evaluation, 
Authorization	, and 	
Restriction of 
Chemicals	 	
Promote the maintenance of 
biodiversity, taking account 
of economic, social,	 cultural 	
and regional requirements 
and making a contribution 
to sustainable development	 	
Environment 
- ecosystems	 	
Reduce and manage regional 
ecological risk	 	
Habitats Directive

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andrea.rudy
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Mac OS X 10.10.5 Quartz PDFContext
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2016-02-12T12:45:29+00:00
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2016-02-12T12:45:29+00:00
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