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Journal of Contemporary China
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Integrating and Prioritizing Environmental Risks in China's Risk
Management Discourse
Lei Zhang; Lijin Zhong
Online publication date: 27 January 2010
To cite this Article Zhang, Lei and Zhong, Lijin(2010) 'Integrating and Prioritizing Environmental Risks in China's Risk
Management Discourse', Journal of Contemporary China, 19: 63, 119 — 136
To link to this Article: DOI: 10.1080/10670560903335835
URL: http://dx.doi.org/10.1080/10670560903335835
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Journal of Contemporary China (2010), 19(63), January, 119–136
Integrating and Prioritizing
Environmental Risks in China’s Risk
Management Discourse
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Human society faces a growing number of risks, including both natural disasters and risks
that stem from human behavior. This is particularly true in China, which is experiencing
rapid social, economic and political transitions. Since the 1970s, China’s modernization
process has been accompanied by the emergence of an increasing number of man-made risks,
in particular environmental pollution, but until very recently, a risk management system did
not exist in China. Society was woken up by a series of disasters and accidents, including
SARS in 2003, followed by the explosion of avian flu and the chemical spill in the Songhua
River in 2005. The last incident in particular finally kicked off the development of a national
risk management system (specifically an emergency response system) in China. This paper
analyses the status quo of the legislation, institutions and mechanisms for risk management in
China and identifies opportunities and strategies for prioritizing and integrating
environmental and health risks into the emerging system. The study concludes that
although a series of alarming incidents have succeeded in putting risk management issues at
the top of the public and political agenda, currently risk management in China can be
characterized as reactive and compartmentalized, with a lack of prioritization and
integration of policy efforts and resources. There is also a danger that the traditional statecentered approach may fail to create an effective risk management system, which requires
improved transparency, accountability, and cross-sectoral coordination. The paper
concludes with the proposal of strategies that might enable the environmental authorities
to be more effective and reduce their marginalization and isolation.
I. Introduction: theories of risk and risk management
Three decades ago, the German social theorist Ulrich Beck declared that we were
‘living on the volcano of civilization’ and that human beings had entered a risk
society.1 His panoramic analysis of the condition of Western societies has already
been hailed as a classic. Beck defined risk management as ‘a systematic way of
dealing with hazards and insecurities induced and introduced by modernization
* Lei Zhang is currently at the Environmental Policy Group in Wageningen University, The Netherlands. Lijin
Zhong is in the College of Environmental Science and Engineering at Tsinghua University, China.
1. U. Beck, Risk Society: Towards a New Modernity, trans. Mark Ritter, Introduction by Scott Lash and Brian
Wynne (London: SAGE Publications, 1992 [originally published in 1986]), 260 pp.
ISSN 1067-0564 print/ 1469-9400 online/10/630119–18 q 2010 Taylor & Francis
DOI: 10.1080/10670560903335835
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itself’. Beck was well ahead of his time in calling attention to the importance of the
concept of risk and the practice of risk management as essential features of modern
society. Developments since his first work have confirmed his view, and there is little
doubt that debates over how to manage risk will increase in their importance.2
In addition to uncontrollable natural catastrophes (such as hurricanes, earthquakes
and volcanic eruptions, where the possible loss is considered to have been caused
externally)3, there is now growing recognition of risks that are generated by
modernization, including environmental/ecological risks that are closely associated
with human health risks, work safety issues and social unrest.4 The interconnection
between human and ecosystem health is now a given: not only is it recognized on an
intuitive level but its significance has also been measured in terms of its contribution
to the burden of disease.5 The World Health Organization, in conjunction with the
World Bank, estimates that 20% of deaths in the developing world are directly
attributed to environmental factors related to pollution and states that proper
environmental management is the key to avoiding the quarter of all preventable
illnesses which are directly caused by environmental factors.6 Many serious public
health problems have been caused by or associated with environmental pollution,7
including, most notably, the Los Angeles smog of 1943, the London smog of 1952,
Japanese Minamata disease in 1953, the Bhopal gas leak disaster in 1984, the Basel
warehouse fire in 1986, and the Baia Mare spill in 2000.
We have begun to understand that economic development can impair public
health if environmental and social considerations are marginalized.8 However,
recognition in academic research of the interactions between environment and social
risks and health has not been echoed in risk management practices. Although risk
management is interdisciplinary in nature, in practice it is excessively
compartmentalized9 and traditional risk assessment and management approaches
designed to deal with the risks of an earlier time have failed to cope with the
2. See William Leiss’s review on Risk Society, Towards a New Modernity by Ulrich Beck, in the website of
Canadian Journal of Sociology online, available at: http://www.ualberta.ca/,cjscopy/articles/leiss.html (accessed
20 December 2008).
3. N. Luhman, Risk, A Sociological Theory (Edison, NJ: Transaction Publishers, 2005).
4. As concluded by the Millennium Ecosystem Assessment, available at: http://www.millenniumassess ment.org
(accessed 20 December 2008).
5. R. T. Di Giulio and E. Monosson, ‘Interconnections between human and ecosystem health: opening lines of
communication’, in R. T. Di Giulio and E. Monosson, eds, Interconnections Between Human and Ecosystem Health
(London: Chapman and Hall, 1996), pp. 3 –6.
6. See WHO website, available at: http://www.who.int/phe/en/ (accessed 20 December 2008).
7. R. D. Gupta, Environmental Pollution, Hazards and Control (New Delhi: Concept Publishing Company,
2006); Jing Fang and Gerry Bloom, ‘China’s rural health system and environment-related health risks’, Journal of
Contemporary China 19(63), (2010).
8. F. Pearce and S. Tombs, ‘Hegemony, risk and governance: “social regulation” and the American chemical
industry’, Economy and Society 25, (1996), pp. 428–454; M. Gandy, ‘Rethinking the ecological leviathan: environmental
regulation in an age of risk’, Global Environmental Change 9, (1999), pp. 59–69; W. Leiss, Smart Regulation and Risk
Management, A Paper Prepared at the Request of the Privy Council Office and External Advisory Committee on Smart
Regulation (Government of Canada External Advisory Committee on Smart Regulation), available at: http://www.
smartregulation.gc.ca; C. Hales et al., ‘Health aspects of the Millennium Impact Assessment’, Ecohealth 1, (2004), pp.
124–128; C. Butler, ‘Peering into the fog: ecologic change, human affairs, and the future’, Ecohealth 2, (2005), pp. 17–
21; P. Weinstein, ‘Human health is harmed by ecosystem degradation, but does intervention prove it? A research challenge
from the Millennium Ecosystem Assessment’, Ecohealth 2, (2005), pp. 228–230.
9. A. Miller, ‘Ideology and environmental risk management’, The Environmentalist 5, (1985), pp. 21–30.
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increasing complexity of risk and its changing social context.10 As Robert and
Lajtha11 have pointed out, the traditional risk management framework is inadequate
and a number of conceptual black holes can be identified. Traditional responses,
which mainly involve policing by the state, have increasingly come to be perceived
as insufficient and unsatisfactory.12
Given the widespread implications of risk management, Griffiths pointed out
that, ‘it is important to strive towards the fullest possible integration of all relevant
inputs’.13 The challenge of the risk society is to create political regimes
and institutions capable of meeting rising public expectations for risk containment
and reduction in the face of the growing pace and complexity of risk generation and
the progressive intertwining of risk with deeper questions of ethics, the social ends of
government, and democratic process.14 To meet this challenge, different models for
risk management have been conceived and practiced in different countries.
Both the European and the American initial risk management systems were
responses to alarming chemical industrial accidents. Of these accidents the Bhopal
gas leak disaster in 1984 led to the greatest number of human casualties, the Basel
warehouse fire in 1986 caused large-scale pollution of the river Rhine, and the Baia
Mare spill in 2000 severely threatened the Danube River. More recently the towns of
Enschede in 2000 and Toulouse in 2001 were seriously affected by chemical
explosions.15 Recognizing the importance of risk management systems for protecting
human health and safeguarding the environment, the 1980s saw the first wave of
legalization and institutionalization in the West, for instance, the Emergency
Planning and Community Right-to-Know Act of 1986 in the United States. This
federal law was a congressional reaction to a number of incidents, most notably the
1984 Union Carbide incident in Bhopal, India, but this law is part of a much broader
set of activities, protests, pressures, and claims in many countries in the 1970s and
1980s, brought together under the right-to-know denominator. In a significant
number of OECD countries, this resulted in right-to-know legislation and information
disclosure provisions in the 1980s (six countries even had them installed in the
1970s). After about two decades of development, both Europe and the United States
have comprehensive systems that are based on multidisciplinary understandings and
that serve as models for the rest of the world. Their experiences also show that the
integration of health, environment and safety management into one coordinated risk
management system is both crucial and cost-effective.16 For instance, the new
National Response Plan (NRP) 2004, which is built on the template of the National
10. R. E. Kasperson and J.X. Kasperson, ‘The social amplification and attenuation of risk’, Annals of the
American Academy of Political and Social Science 545, (1996), pp. 95 –105.
11. Robert and Lajtha, ‘A new approach to crisis management’, Journal of Contingencies and Crisis Management
10(4), (2002), pp. 181 –91.
12. I. K. Richter et al., Risk Society and the Culture of Precaution (New York: Palgrave MacMillan, 2006).
13. R. Griffiths, ‘Acceptability and estimation in risk management’, Science and Public Policy, (1980),
pp. 154 –161.
14. Kasperson and Kasperson, ‘The social amplification and attenuation of risk’.
15. OECD, OECD Guidelines for Chemical Accident Prevention, Preparedness and Response: Guidance for
Industry (Including Management and Labour), Public Authorities, Communities and other Stakeholders (Paris:
OECD, 2003).
16. Ibid.; US EPA, 2004 Year in Review: Emergency Management—Prevention, Preparedness and Response (US
EPA), available at: http://www.epa.gov.
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Incident Management System (NIMS), is an all-discipline, all-hazards plan that
establishes a single, comprehensive framework for the management of domestic
incidents, the OECD Guiding Principles for Chemical Accident Prevention,
Preparedness and Response (1992 first edition to 2003 second edition). Indeed, one of
the common trends in these countries and regions is that environmental security is
gaining in importance in overall risk management, although this has not translated
into pragmatic institutional arrangements that enable the integration of environmental risk management into the system as a whole.
Theoretical discussions and empirical observations highlight the fact that
environmental risks are, in many cases, the causes and/or the consequences of other
types of risks or incidents. Given the fact that environmental risk is an integral
dimension of contemporary production processes,17 the greatest benefit of integrating
environmental risks into a systems context is that it provides a framework for
considering the costs and benefits of strategies for prevention and mitigation.18 For
this reason, the importance of environmental risks and incidents, which are
more controllable and preventable than those generated by natural processes, should
be recognized and given more attention as risk management systems are established
or modified.
There is now a consensus that an effective risk management system should
include the following elements: prevention, preparedness, response and recovery
(see Figure 1). But while it is easy to understand the necessity of these four steps in
risk management, it is a real challenge to weigh risks and set priorities across
different risk categories, to create institutions that guarantee cross-sectoral
coordination, to allocate resources effectively and to address underlying social
characteristics, structures or processes.19 As we I have argued in the second
paragraph above, the connection between environmental risks and other types of risks
justifies the prioritization of environmental risk management in the broader system.
Given the long-term impacts that environmental incidents can have on affected
populations and the environment, recovery is far from an easy and one-time task, but
rather one that requires different actions and involves different actors and long-term
commitment as well as the investment of resources.
Managing a ‘double risk society’: the China case
If the distribution of ‘bads’, with globalizing ecological risks primary among them, is
a dominant characteristic of the affluent ‘risk-society’,20 the mixed importance of
both the fair distribution of ‘goods’ (such as wealth and social benefits) as well as the
‘bads’ (such as pollution and health damage) has made many developing countries
and the ones in transition ‘double-risk’ societies.21 As a country in the midst of rapid
17. Gandy, ‘Rethinking the ecological leviathan’; Pearce and Tombs, ‘Hegemony, risk and governance’.
18. Bartell S. Dale et al., ‘Systems approach to environmental security’, Ecohealth 1, (2004), pp. 119 –123.
19. J. Salter, ‘Risk management in a disaster management context’, Journal of Contingencies and Crisis
Management 5, (1997).
20. Beck, Risk Society.
21. L. Rinkevicius, ‘The ideology of ecological modernization in “double-risk” societies: a case-study of
Lithuanian environmental policy’, in G. Spaargaren, A. P. J. Mol and F. H. Buttel, eds, Environmental Sociology and
Global Modernity (London: SAGE Publications, 1999).
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Figure 1. Integrated risk management system prioritizing environmental risk.
and extensive social, economic and political transitions, which have stirred up many
deeply rooted conflicts and problems in society as development moves forward,
China is a typical ‘double-risk’ society.22
Over the past three decades, China’s economic explosion has created an ecological
implosion. Environmental degradation is costing the country nearly 9% of its annual
GDP.23 Overdevelopment and the poor management of rivers, forests, grasslands,
and land affect the livelihoods of rural and urban residents, and both rich and poor.
Biodiversity is increasingly threatened, and the impact of pollution on people’s health
is severe. Environmental pollution is blamed for the rise in cancer.24 The number of
premature deaths in China caused by respiratory diseases related to air pollution is
750,000 a year (a more conservative estimate by SEPA is 400,000 a year).25
In addition, the environment has become one of the leading causes of rising social
unrest in China. In 2004 the government recorded 74,000 mass protests and in 2005
the number of criminal cases related to public disorder was reportedly as high as
87,000. In 2005, the international and domestic media were kept busy reporting on
numerous environmental protests, several of which spiraled out of control, resulting
in beatings, arrests, and even deaths.26
The industrial sector contributes about half of China’s GDP but also generates serious
risks for society and the environment. Despite China’s increasingly vigorous efforts to
curb industrial pollution over recent decades, industry remains the principal culprit of
22. L. Zhang, Ecologizing Industrialization in Chinese Small Towns, unpublished Ph.D. dissertation, Wageningen
University, 2002.
23. J. L. Turner and L. Zhi, ‘Chapter 9: Building a green civil society in China’, in State of the World 2006:
Special Focus: China and India, available at: http://www.worldwatch.org/node/4000 (accessed 20 December 2008).
24. According to a Health Ministry survey in 30 cities and 78 counties, available at: http://planetark.org/
dailynewsstory.cfm/newsid/41947/story.htm (accessed 20 December 2008).
25. China: Growth—and Growing Pains, available at: http://www.thefreelibrary.com/China:þ Growth –
andþ growingþpains.-a0177072018 (accessed 20 December 2008).
26. E. Economy, ‘The lessons of Harbin’, Time Asia Magazine 166, (5 December 2005), p. 23; J. L. Turner,
working paper ‘China’s environmental crisis: opening up opportunities for internal reform and international
cooperation’ http://www.chinabalancesheet.org/Documents/PaperEnvironmentPaper.pdf (2006).
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environmental degradation and threats to public health.27 To take the petro-chemical
industry as an example: in 2004 the output of this sub-sector increased by 32.3% over
2003 and accounted for 18% of the national GDP. Demand-driven expansion of the scale
of production necessarily increases the risks and the risk is heightened by the fact that
most of these potential ‘bombs’ are located along major rivers and lakes and in densely
populated areas. By 2006, there were 21,000 chemical plants along rivers in China and
half were on either the Yangtze or Yellow Rivers, the country’s two main and most
populated arteries.28 Within two and a half months of the chemical spill in the Songhua
River on 13 November 2005, SEPA received 45 reports of environmental accidents,
including a cadmium spill into the Beijiang River in Guangdong province.29 The
question is not whether similar incidents will occur in the future, but when and where the
next one will happen and what we can do to prevent and prepare for it.
As a latecomer in this field, China can learn a lot from international experience.
At the same time, the risks China faces are more acute than in developed countries,
and China lacks the institutional capacity and social infrastructure required to cope
with these risks. This implies that China has to find a more effective and affordable
solution for safeguarding its modernization project. Figure 1 shows what such a
solution might look like. The most important feature of this proposed
solution/strategy is prioritizing environmental risks and focusing on prevention and
preparedness. Given the fact that China needs to build its risk management capacity
in social, economic and political contexts that differ from those in the Western world,
more China-specific systems need be created to protect people and the environment
there. The remainder of this article analyzes the status of current legislation,
institutions and mechanisms of Chinese incident management and identifies
opportunities and strategies for integrating environmental elements into the emerging
system. Section II further analyzes recent developments in the Chinese system, which
leads to recommendations for strengthening the system.
II. Chinese risk management system in the making and its characteristics
Although various man-made risks, especially ecological/environmental risks, have
accompanied and been intensified by economic reform in China since the end of the
1970s, there was until recently, no risk management system in China. Effectively, the
country was like a person with no immune system.
China has only recently begun to respond to the increasing risks associated with its
current mode of development. Arguably, two major events marked the rather short
history of the Chinese risk management system (which has mostly taken the form of
emergency response), namely, SARS in 2003 and the chemical spill in the Songhua
River in November 2005.30 In the wake of SARS, the term ‘state of emergency’ first
27. H. Shi and L. Zhang, ‘Environmental governance of China’s rapid industrialization’, Environmental Politics
15, (2006), pp. 272–293.
28. US EPA, 2004 Year in Review.
29. SEPA, News Release on Recent Environmental Accidents, available at: http//:www.zhb.gov.cn.
30. The first city-level risk management system was started in Nanning, the capital city of Guangxi Zhuang
Autonomous Region in May 2002. Shanghai was the first among provincial level governments which started to
formulate its overall emergency response plan in 2001: available at: http://www.enorth.com.cn (accessed 9 January
2006). However, these local practices did not attract political and public attention at that time.
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appeared in China. In fact, shortly after SARS, the modified Constitution 2004
changed the term ‘enforcement of Martial Law’ to ‘state of emergency’. This
modification indicates the shift of political attention from the traditional focus on
political stability to other domains, including major natural or human disasters and
emergencies, and marks the beginning of legislation on public risk management. Not
surprisingly, the first piece of legislation after SARS was the ‘Public Health
Emergency Response Ordinance’ issued in May 2003. In September 2003, the
Beijing municipal government issued its Response Plan for the Prevention and
Control of SARS.
In order to formulate the National Emergency Response Plan, a working group was
formed in July 2003 under the leadership of the State Council. In May 2004, the State
Council circulated the ‘Guidelines for Formulation of Emergency Response Plans by
Provincial/Municipal Governments’ and urged local governments to report their plans
to the State Council before the end of September 2004. In January 2005, Premier Wen
Jiabao approved the National Emergency Response Plan, together with 25 Specific
Thematic Plans and 80 Sectoral Plans. On 22–23 July 2005, the State Council called
for the first National Working Conference on Public Incident Management, which
marked the start of the institutionalization of public risk management in China. On 8
January 2006 when the State Council officially issued the National Emergency
Response Plan, all the provinces and municipalities had completed their plans.31
In the ‘Guidelines’ of the State Council, public incidents are defined as emerging
public incidents, natural or manmade, that cause major casualty, loss of property,
ecological and environmental damage and social threats. These incidents are further
divided into four categories: natural disasters (earthquakes, floods, hurricanes,
tornadoes, tropical storms, forest fires, biological disasters, etc.); catastrophic incidents
associated with industrial production, traffic and transportation, public works, and
environmental pollution and ecological damage; public health and medical
emergencies (epidemics, food safety and other incidents that threaten public health
and safety); and civil disorder (terrorist attacks, economic crises and diplomatic crises).
Incidents are graded using a four scale according to their nature, severity, susceptibility
to control, etc., with Grade I being the most severe (see Table 1). Obviously, this
definition does not recognize the weight of environmental risks and their relationship
with other risks, as we argue should be done. Consequently, the emergency response
plans do not reflect a sufficient integration of environmental considerations and there is
a lack of cross-sectoral coordination and cooperation in practice.
Not surprisingly, after the explosion of the chemical plant, the newly formulated
emergency response plans in Jilin, Heilongjiang and Harbin were found not to have
been fully functioning. The first reaction from the local government after the
explosion focused only on production safety, without taking into account the
environmental pollution consequences and its affect on the drinking water supply,
which could have been avoided or mitigated if proper measures had been
taken quickly.32 Thus, this accident glaringly exposed the weaknesses within the
current risk management systems in terms of the legal framework, institutional
31. ‘The establishment of Chinese incident management system’, China Youth Daily, (8 May 2006).
32. J. W. Chang, Rethinking Songhuajiang Pollution Incident: Problems in Chinese Environmental Legislation
(China Institute of Law), available at: http//:www.iolaw.org.cn/.
Table 1. The classification of public risks in China
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Risk categories of Chinese ERS
Public health and
medical incidents
storms, earthquake,
biological disaster,
wildland/forest fire, etc.
Work safety,
accident, public
damage, etc.
Epidemic, unknown
disease, food safety,
animal epidemic,
and other occurrences
threatening public
health and safety
crisis and
crisis, etc.
capacity, and the efficacy of the response measures taken, as well as other
‘unstructured factors’ such as awareness, public participation, transparency and
freedom of information.
Legislation pertaining to risk management in China is a typical example of reactive
law making. Although prior to 2003 China had a few relevant laws governing the
enforcement of martial law, the mitigation of the consequences of earthquakes, and
flood prevention and production safety, the legal framework for public incident
management was fragmented and inadequate. As of 2007 existing laws dealt
mainly with specific or sectoral risks, not recognizing the weight of environmental
risks and the ways in which they are connected to public health and other risks.
The range and severity of risks in China today calls for the creation of a more
comprehensive and coordinated risk management system with a more solid legal
base. This is why an emergency response law was drafted as an expedient response
to SARS in 2003. The Emergency Response Law came into effect from 1
November 2007. This law is an important legal base for building a risk
management system in China, although it focuses only on one of the four elements
of the risk management cycle.
Apart from specific laws directly addressing certain risks, there are only a few
clauses within environment-related legislation that can guide and support integrated
environmental risk management. For instance, the only relevant part in the Chinese
Environmental Protection Law 1989, Article 31, specifies
. . . in the event of the occurrence of incidents that cause or might cause pollution, the
responsible organization must take control actions, inform affected organizations and
citizens, and report to the local Environmental Protection Bureau and other relevant
authorities. Potential polluters should take necessary measures to prevent and control
pollution incidents.
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But Article 31 does not give a clear definition of what an environmental incident is or
make specific requirements regarding emergency responses, such as warning
systems, reporting, information disclosure, impact assessment, legal responsibilities,
recovery, etc. In addition, this law does not require industries to install emergency
systems and does not overcome the horizontal and vertical compartmentalization of
tasks and responsibilities across authorities; nor does it indicate how this law relates
to other relevant legislation, such as the Epidemic Prevention and Control Law and
the Work Safety Law. This ambiguity is also reflected in other laws
regarding emergency responses to environmental problems, such as legislation
regarding the prevention and control of water, air and solid waste pollution, various
ecological damage prevention and control laws, and the environmental administrative law.33
Overall, the current legislation does not provide a sound base for the creation of a
comprehensive national incident management system which recognizes the importance
of environmental risk prevention and control and justifies the integration of
environmental risks into other sectors. The current emergency management system
focuses only on responses to the disasters that have already occurred, which is only one
of the elements in a complete and effective risk management system that
includes prevention, preparedness, response and recovery. It is too early to say how
the emergency response law will overcome these weaknesses in the legal system
and how environmental risk can be fully integrated into other emergency response plans.
Furthermore, the effective implementation of emergency response plans requires
legally-mandated and institutionalized freedom of information and, community rightto-know measures. It must also address issues of compensation, liability and
responsibility for organizing recovery after incidents, many of which are not yet on
the agenda of the Chinese legislators.34 Although the Environmental Information
Disclosure Decree took effect on 1 May 2008, a survey we have conducted on its
implementation concludes that it is seen by the majority of EPBs as a burden, and
that only lip service is paid to information disclosure.35
Institutional building
Arguably, a formal institutional network for comprehensive emergency management
did not exist in China before SARS. An ad hoc National Emergency Response Office
within the State Council was quickly established as a liaison point between the
State Council and other governmental authorities in 2006 after the Songhua
River pollution incident.36 This Office organizes resources for the formulation of the
National Emergency Response Plan, approves other specific thematic
emergency response plans, and guides the practices of other ministries and local
33. J. W. Chang, Problems and Countermeasures Regarding Legislation for Environmental Incident Management
in China, available at: http//:www.h20-china.com.
34. J. W. Chang, Foreign Experience in Environmental Legislation of Public Participation and Lessons for China
(China Institute of Law), available at: http//:www.iolaw.org.cn.
35. L. Zhang, A. P. J. Mol and G. Z. He, unpublished working paper ‘Environmental governance and information
disclosure in China’, submitted to Environmental Science & Technology.
36. See ‘Circular regarding the establishment of State Council Emergency Response Office’, Policy Paper No. 32
by the General Office of State Council, 10 April 2006.
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governments.37 It is also responsible for coordination among different organizations
and mobilizing the resources needed in case of emergency. Given its current capacity
and authority, it is doubtful that this Office can influence the legislative bodies and
other governmental authorities in terms of institutional building and legislation.
In order to build up a nationwide institutional network, the State Council has urged
its ministries and departments to set up their own offices to be responsible for the
formulation and implementation of their emergency response plans. This has led to
increases of staff, budgets, and training in these organizations.38 Governments at
various levels are responsible for incident management work following the practices
at the national level (Figure 2). Outside government, enterprises and organizations
are also required to make their own emergency response plans. However, nothing is
said about the contents of these plans or how they will be monitored.
Cities have been creative in designing and developing their own risk management
systems. Four different models have emerged so far, represented by Beijing,
Shanghai, Guangzhou and Nanning. Each model presents a different kind of
leadership, reflecting an emphasis on different risks and different agencies. Beijing
and Nanning have created an overarching commission or center, while Shanghai and
Guangzhou have built onto existing departments. These models set examples for
other cities to be innovative in creating their institutional arrangements to fit their
own situations (Table 2). It is noted that in all four of these models, environmental
risk and its integration with other risk management is generally neglected.
Given the past record of rather unsuccessful attempts to integrate environmental
concerns into the scope of work of other sectoral departments in China, SEPA is
challenged by the question of how to enable environmental elements to penetrate other
plans. This partly explains why in the National Environmental Emergency Response
Plan (one of the theme-based plans), certain responsibilities, such as coordination
among different authorities, implementation of environmental emergency responses,
the establishment of an early warning system for environmental incidents, formulation
of the National Environmental Emergency Response Plan, public awareness raising
and the official release of information, are left to the National Inter-Ministerial
Conference for Environmental Protection (NIMCEP). But the NIMCEP, which was
convened in 2001 by the State Council for Inter-Ministerial Coordination on
Environmental Issues39 is a body that only meets occasionally to respond to specific
events, and it is based on loose networks. Although it facilitates the exchange of
information about environmental problems across sectors, the NIMCEP’s decisions
have no legitimacy. In this situation, it is far from clear how SEPA and its local
counterparts can play a strong role in the emerging risk management systems in China.
37. At the time of writing, 80 sectoral emergency response plans and 25 subject-based emergency response plans
had been formulated. The National Emergency Response Plan for Environmental Incidents is one of the subject-based
plans issued by the State Council. General Office of the State Council, ‘Emergency Response System Framed’,
5 August, 2006, at: http://www1.www.gov.cn/ztzl/content355022.htm.
38. For instance, the State Work Safety Supervision Administration (SWSSA) planned to add 80 staff in its
Emergency Response Headquarters, which was established in January 2006. During the 11th ‘Five Year Plan’ of the
SWSSA, 20.3 billion Yuan will be allocated to establish its vertical emergency response system, including six
regional relief stations, 11 sectoral aid systems, 31 provincial headquarters and 333 municipal branches. See New
Beijing Daily, (13 March 2006), available at: http://www.sina.com.cn.
39. SEPA, Major Events of Environmental Protection 2002, available at: http//:www.sepa.gov.cn.
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Figure 2. Four-level emergency response system in China.
Measures and actions
The central government’s call for risk management has been received by different
departments in different ways. New measures and actions have been taken to raise
awareness, to improve the information of freedom, to build institutional capacity, to
institutionalize public participation, and so on. It is good to see that communicating
with the media during emergencies was a topic in the training of the relevant official
spokesmen/spokeswomen in workshops recently organized by the Information Office
of the State Council.40 The State Work Safety Bureau has launched a training project
for emergency response at the central and local levels for governmental officials,
responsible managers of industries and organizations.41 Although this is the most
systematic training project on this issue so far, the bulk of the training material
focuses on work safety and public health. The management of environmental
incidents is mentioned only briefly and none of the trainers is an environmental
To a large extent, the increase in environmental pollution accidents in recent years
is the result of limited monitoring capacity and the lax enforcement of environmental
regulations. Campaign-style reactive responses may succeed in attracting attention
from the media and the public, as well as support from local governments for a short
time, but the effects are often short-lived and there is rarely adequate follow-up.
During a national telephone working meeting on responses to environmental
incidents on 1 December 2005, SEPA required other EPBs to increase their
awareness and capacity for emergency responses, to focus on prevention through
40. According to a speech by Cai Wu, the director of the Information Office of State Council, available at: http://
www.enorth.com.cn (accessed 3 December 2005).
41. State Administration of Work Safety (2006).
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Table 2. Four models of city emergency response systems in China
Executive institution
Beijing Public Emergency
Response Commission
Beijing Emergency
Response Headquarters in
the General Office of the
Beijing Municipality
Shanghai Disaster
Mitigation Leading Team
Guangzhou Social Jointaction Service Team
Nanning City Emergency
Response Center, a
governmental agency
reporting directly to the
Nanning Government
Shanghai Emergency
Response Center in the
Shanghai Public Security
Bureau plus operating
arms based in different
relevant departments
Guangzhou Social Jointaction Center in the
Guangzhou Public
Security Bureau
Nanning City Emergency
Response Center
Coordinate cross-sectoral
interests and responsibilities via commission and
stress the status of Beijing
as the capital city
Small headquarters and
big network based on
existing facilities and
Rely on the existing
capacity of the Public
Security Bureau
Creation of a new hightechnology-based center
for emergency response
more publicity activities and to establish effective systems for reporting incidents.
SEPA also specified the procedure for reporting incidents within the EPB system in
March 2006,42 but it is not enough to raise risk awareness and capacity only within
the SEPA (the Ministry of Environment since March 2008) system. It is more
important to make environmental responsibility part of decision making in other
In recent years there has been an increase in the number of investigations and
disciplinary actions taken against officials and government personnel responsible for
wrong doing. In 2005, 17 officials were found by SEPA to be responsible for nine
incidents. During a recent meeting of the Standing Committee of the National
People’s Congress, the newly appointed environmental minister, Mr Zhou
Shengxian, called for local governments to give more protection and support to
local environmental officers.43 The new minister expressed his intent to change the
situation in which the directors of local EPBs are forced to choose between local
economic interests on the one side, and the enforcement of environmental regulations
on the other. However, it is not yet clear how he can make government officials pay
for their environmentally damaging behavior.44 The problem is fundamentally the
same when it comes to making local officials responsible for environmental risk
42. SEPA, ‘Circular on “Environmental incidents reporting measures” (trial)’, SEPA Policy Paper 59, (2006).
43. ‘Will public participation help environmental protection?’, China Daily, (22 May 2006).
44. ‘Protect the EPB directors’, People’s Daily, (22 May 2006).
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In general, public information and participation in risk management are still
limited. Governmental and market failures mean that it is essential for the public to be
involved in environmental governance, including environmental risk management. A
strong trend towards greater openness on environmental problems can be observed in
the wake of the various incidents that have occurred in recent years. To open the
political space for public participation in environmental governance and risk
management, the Chinese government has finally started to take substantial actions
rather than merely paying lip service to public participation. The recent decision of
the State Council on ‘The Scientific Development Outlook and Enhancing
Environmental Protection’ stresses that ‘ . . . developmental plans and construction
projects must be decided on the basis of sufficient public participation and under
public supervision by conducting public hearings or public announcements’. SEPA is
actively responding to this call and is now working on ‘Measures Regarding Public
Participation in Environmental Protection (trial)’ as an attempt to institutionalize
public participation and to help SEPA conduct its work. This will be the first
document to specify detailed procedures for public participation on environmental
issues.45 SEPA was the first agency in China to issue regulations and actually hold
public hearings based on the new Administration Permission Law passed in July
2004,46 and the Environmental Information Disclosure Decree 2007 was the first
effort by a particular sector to operationalize the general regulations on Open
Governmental Information. Although the government remains wary of too much
citizen activism, China’s top leaders recognize that government needs help to address
a broad range of emerging social and environmental ills and to keep local
governments in check, especially in light of the downsizing of the central government
and the growing power of the local governments. Chinese environmental NGOs were
the first to register as social organizations and now form the largest sector of civil
society groups in China (nearly 2,000 in number).47
Inadequate technical capacity and support is another problem. Apart from the
participation of the public and NGOs, the formation of subject-specific expert team is
an integral part of an emergency response plan. Decision making in responding to
emergencies must be based on scientific evidence. While it is easier for the central
government to access and mobilize expertise when incidents occur, it can be
impossible to obtain this technical support at the local level. Therefore, it is necessary
to establish an information-sharing mechanism to maximize the benefit of expert
resources. In addition, as part of institutional capacity building, expert teams need be
formed to provide various kinds of technical support. As a preparedness measure,
research that can inform how to respond in case of incidents should be promoted for
chemicals that are produced on a large scale. Internet-based websites can play an
important role in information and knowledge sharing, for example, the Longgang
Information Net for Emergencies.48 Along with the formulation of emergency
45. Ibid.
46. Administration Permission Law requires administrative agencies to inform citizens of their right to express
their opinions at public hearings regarding any government project that impacts them (Tang et al., 2005); Turner,
‘China’s environmental crisis’.
47. Turner, ‘China’s environmental crisis’.
48. See http://www.ics.lg.gov.cn/default.asp.
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response plans, some governments or organizations have conducted various exercises
simulating emergencies.49
All these activities, including awareness raising, training, the creation of new
offices, recruitment of new staff and experts, the installation of monitoring systems
and information systems, research on technical responses, and recovery measures,
require capital, material and human inputs. For instance, Nanning Municipality has
invested 170 million RMB for the construction of an emergency response system
including a headquarters and five extended bases which cover an area of 10,029
square kilometers. This high-tech system follows the American 911 system, and was
built with technical cooperation with Motorola. It is not difficult to calculate the
investment that would be required if the whole of China were to choose a similar
system.50 China’s risk management system has to compete for resources with other
urgent needs. The newly issued Guideline for the 11th Five Year Plan devoted one
chapter to risk management and hopefully this will lead to increased investment in
this field as investment now will prevent greater losses in the future. Given the limited
resources in China, it is extremely important to assess the weight of different risks
and to identify priorities. Focus should be put on preventive measures to avoid the
huge cost of response and recovery afterwards. For example, China has earmarked
26.6 billion RMB (US$3.3bln) to make water from the poisoned Songhua
River drinkable by 2010.51 This expense could have been saved if a more effective
response plan could have been implemented immediately after the explosion.
Obviously, this is a formidable task for China and international assistance is badly
needed. On the one hand, as a latecomer, China should take the opportunity to learn
from other countries in developing its risk management system. International
cooperation can also help China reduce investment in R&D activities, avoid repeating
the same mistakes, and improve communication during transboundary disputes.
III. Strategies for risk management integrating and prioritizing
environmental risk
Judging from current developments in China regarding risk management, it is fair to
say that the newly emerged risk management system is a kind of ‘quick and dirty’
reaction on the part of the Chinese government, which focuses only on responding to
emergencies. The Songhuajiang incident should not be merely viewed as exposing
the shortcomings in the emergency preparedness of industry. It also exemplified the
institutional weaknesses that underlie nearly all environmental and risk management
problems in China—local government protectionism, insufficient government
transparency, weak and understaffed environmental enforcement agencies,52
49. SEPA, Announcement on Observing Environmental Emergency Response Rehearse, available at:
http//:www.zhb.gov.cn; ‘SEPA switches on its Environmental Emergency Response Plan in Huai River Basin’,
People’s Daily, (30 April 2005); ‘Xie Zhenhua says: environmental indicators for performance evaluation of
government officials’, Xinhuanet, (18 November 2005).
50. Nanning City Emergency Response Center: The First in China, available at: http://www.nanning.gov.cn/
(accessed 9 August 2004).
51. ‘China has earmarked 26.6 billion yuan to make water from its Songhua River drinkable’, Beijing Youth
Daily, (8 January 2006).
52. SEPA has just fewer than 300 staff.
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compartmentalized policy efforts, the absence of a coordinated legal framework, and
a pervasive lack of mechanisms for informing and involving the public in
environmental protection and risk management.53 Although issues like public
participation and freedom of information are stressed when it comes to risk
management, the actual legal and institutional structures in place are not really
different from the traditional add-on solutions. They do not address the reality of
what a disaster is: a wake-up call signaling that without real reform, there is the risk
of hundreds of millions of citizens becoming desperately ill citizens, greater social
unrest and, perhaps even the end of the Chinese economic miracle.54 Finally, there is
no clear strategy regarding risk management in China today that is designed to
achieve cost-effectiveness and safeguard economic development by prioritizing
environmental risks and following preventive principles.
In this rather gloomy picture one hopeful sign is that during the NPC and the Chinese
People’s Political Consultative Conference (CPPCC) in March 2006, the issue of
public incidents management, especially environmental security, was in the political
spotlight. Both the NCP representatives and CPPCC members raised bills that
emphasized the strategic significance of environmental security, including calls for an
all-in-one coordination institution for national security that would stress environmental security, the further empowerment of SEPA in enforcement and enhancing
vertical and horizontal co-ordinations, legislation for environmental emergency
responses and so on.55 Although not yet law, these calls for action indicate an active
institutional dialogue on the integration of risk management and the prioritization of
environmental security. As part of the institutional reform package approved by the
11th NPC in March 2008, SEPA was upgraded to the status of Ministry of Environment
Protection. This shows that the top policy makers are fully aware of the importance of
environmental security and its relationship with other sectors. Of course, translating
this political will into actual political and institutional reforms at the local levels is not
something that will take place automatically. Nevertheless, this seemingly chaotic
situation opens opportunities for reshaping environmental governance and risk
management in favor of the ministry and its mission.
Indeed, the new head of the MEP picked up this political signal in no time.
The ‘Scientific development outlook’ might sound like an empty slogan, but China’s
environmental chief Zhou Shengxian said that the slogan ‘has equipped me with a
very powerful weapon. If I use this weapon properly I will not end up resigning’.
Zhou also said the growth at any cost approach was changing.56 Wisely riding on the
wave of the Songhuajiang incident, SEPA included in its work plan for 2006 a list of
tasks that included improving enforcement of environmental regulations, building up
early warning systems and emergency response plans, implementing measures for
reporting environmental incidents, and monitoring potential key polluters. To this
end, SEPA had been focusing on the enforcement of EIA, total pollution load control,
53. Turner, ‘China’s environmental crisis’.
54. Economy, ‘The lessons of Harbin’.
55. ‘Environment as the hot issue during NPC and CPPCC’, China Environmental News, (7 March 2006).
56. Lindsay Beck, China Warns of Disaster if Pollution not Curbed, available at: http://www.planetark.org/
dailynewsstory.cfm/newsid/35596/story.htm (accessed 13 March 2006).
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investigating and disciplining officials and promoting public participation and
international cooperations in this field.57
However, given the nature of environmental risk and its connectedness with other
risks, it is not possible for SEPA to address environmental problems and risk
management issues without delegating the tasks to and involving other departments
and actors. Therefore, SEPA should adjust its position in China’s risk management
from an isolated sector to an embedded element in other risk management systems.
Otherwise, SEPA’s efforts to improve its own response will have limited effect and
SEPA will be kept busy running after incidents caused by the problems rooted in
other fields, and will find itself responsible for clean-up, while at the same time being
blamed for an inadequate response, just as it was in the Songhua River case.
In order to improve its position in the overall risk management system and reduce
its isolation, SEPA can focus strategically on three actions: lobbying for an improved
legal framework for integrated risk management; institutionalizing public
participation; and formulating a plan for both internal and external communications.
The modified Constitution 2004 laid a good base for other law making pertaining
to risk management in general. However, only if the strategic position of
environmental protection and environmental risk management is recognized in the
law on emergency responses will it be possible to integrate various incident response
plans into one system for maximum effectiveness. In addition, the current
Environmental Protection Law needs to be modified to respond to the growing
environmental risks along with the rapid industrialization process. Only with this
legal framework in place will it be possible to integrate environmental education, the
environmental responsibilities of the various levels of governments, freedom of
information, and public participation in environmental impact assessment for
development planning and projects. Accordingly, all the other specific environmental
laws should include incident management as an integral component. Since
environmental accidents also involve environmental security assessment, the
declaration of a state of emergency and, in some cases, the mobilization of military
forces and diplomatic communication, it is also necessary to make a law for
environmental incident responses that is approved by the Standing Committee of the
NPC or an ordinance by the State Council.58 Given these considerations, MEP
should take this opportunity to present a more integrated proposal to law makers so
that environmental protection becomes, by law, a responsibility of all the other
departments. Then the MEP and local EPBs would be able to concentrate on
enforcing the regulations and supervising the performance of other agencies.
One of the common features of environmental protection legislation around the
world is the principle that environmental protection should be based on public
participation and the public’s right to know.59 Although this is also one of the
principles of Chinese environmental law, it has never been clearly defined or
institutionalized. Public participation is not yet recognized as a basic human right
57. ‘Guiding principles for environmental protection in China’, China Environmental News, (16 February 2006);
SEPA, ‘Circular on “Key points of National Protection Work Plan 2006”’, SEPA Policy Paper 8, (2006).
58. Chang, Problems and Countermeasures.
59. Chang, Foreign Experience in Environmental Legislation; Environmental Law Network International,
International Environmental Impact Assessment (Bingen: ELNI, 1997).
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in either the Constitution or the Environmental Protection Law and the public
(whether as individuals or social organizations) is often absent from environmental
governance. MEP should continue to raise its voice in support of greater public
participation by working closely with mass media, NGOs and environmental activists.
This strategy will also help MEP with environmental monitoring and supervision.
Enhancing public participation should not dilute the responsibility of the
government in incident management in China. On the contrary, the increasing
frequency of incidents in China challenges deep-rooted administrative traditions,
attitudes and approaches, and highlights the need for more transparency and reliability.
To respond to this, a series of new measures have recently been issued to guarantee
collective decision making for major public projects, an expert support system, public
hearings and announcements, the release of information and investigations into the
parties responsible. MEP is also working on new measures to enforce public
participation in Environmental Impact Assessments of public plans. Environmental
indicators will be included in the evaluation of officials’ work performance as initially
proposed by the former environmental minister, Mr Xie Zhenhua.60 In fact, MEP has
already modified the criteria to qualify as an ‘Environmental Protection
Demonstration City’ by adding an indicator for the capacity to respond to
environmental incidents in April 2006, which will have veto status in the evaluation
process.61 These are very positive and timely moves.
Communication is an important instrument an organization can use to achieve its
goals but communication plans are often neglected by Chinese organizations when a
policy or a project is implemented. If MEP adopts a strategy of promoting an
integrated risk management system, then the next steps should be: (a) analysis of the
issues; (b) outlining the role of communications; (c) identifying target groups; (d)
determining communication targets; (e) determining the communications strategy/messages; (f) determining the means; (g) budget; (h) organization; (i) implementing;
and (j) evaluation. A number of methods of communication can be employed to
achieve a specific objective, for instance, regular opinion and attitude surveys, mass
media content analysis, ongoing networking with NGOs, interest groups and scientific
institutions, and regular briefings and interviews and meetings with interest groups
and the press, participating in various trainings on risk management, etc. It would also
be useful to further formalize the existing National Inter-Ministerial Conference for
Environmental Protection and to bring environmental security issues into its
discussions. Combining the force of the ‘auditing storm’62 and the ‘environmental
storm’63 can also enable MEP to make a bigger impact with fewer resources.
Chinese risk management is in its infancy. Much remains to be done but the field
has the potential to make a strong contribution, and win positive recognition. MEP
60. ‘Xie Zhenhua says’, Xinhuanet.
61. SEPA, ‘Circular on “Environmental incidents reporting measures” (trial)’.
62. 2004 witnessed the shocking impact of the auditing reports published by the China National Office of the
Auditor on sensitive issues like corruption among governmental officials, misuse of governmental budgets, etc. Many
high ranking officials fell during this ‘auditing storm’. See: http://www.xinhuanet.com (accessed 28 December 2004).
63. In 2005, more than 30 large-scale construction projects were stopped by SEPA because they failed to carry out
Environmental Impact Assessment. Henceforth, SEPA increased its scrutiny of major potential polluters. These
actions are labeled as ‘environmental storm’. See: http://www.xinhuanet.com (accessed 28 September 2005).
should take this opportunity to push the central government for real reforms which
can support development based on scientific approaches.
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IV. Conclusions
As Rob Swart predicted more than ten years ago,64 the ‘environment-related security
risks associated with “conventional development” have not only increased but it will
be years before we have full knowledge of their impact on social, economic, political,
and institutional conditions and their environmental consequences’. Environmental
factors are very important in addition to political, social and economic factors in
bringing about civil strife and vital damage to the public. Time is not on China’s side
to protect its people from the risks associated with modernization. Even if the lack of
institutional preparation for the sudden and unexpected outbreak of SARS was
tolerable and the subsequent mitigation measures were respectable, the chemical spill
in the Songhua River made it extremely clear that the country needs to establish
institutions and mechanisms for contingency responses to emergencies and the
effective implementation of those plans. An effective risk management system is
important not only in order to respond quickly to incidents, but more importantly to
prevent incidents from happening.
The absence of government strategies to prevent and respond to risks is now
recognized and efforts have been made to change this situation,65 but although the
rapid formulation of emergency response plans in China is a good sign, it must not be
the end of the story. Concrete actions need to be taken to establish a national
information platform for emergencies, make training and publicity plans, invest in
research and development and form subject-specific expert teams. Beyond all this,
awareness of and responsibility for environmental risks must be not only felt but also
borne by the whole society. Increasing attention to environmental security has opened
up new space for MEP and EPBs to operate. Since the current evidence does not
support the creation of an integrated risk management system in China, it is wise for
the ministry to take appropriate actions to bring a new order to the chaos. The new
ministry should take all opportunities to systematically highlight and support nascent
Chinese policy efforts to introduce integrated risk management. It can also build
confidence and help to foster positive and constructive interagency interactions by
facilitating cooperation across lines of tension.
Given the recent nature of China’s efforts to establish a risk management system, it
is clear that many questions remain, especially at the operational level, and that
further research will be needed as the system evolves. This paper represents only an
initial attempt to identify strategies that the Ministry of Environment might employ
to further the development of an effective and integrated risk management system
that prioritizes environmental protection.
64. Rob Swart ‘Security risks of global environmental changes’, Global Environmental Change 6(3), (1996),
pp. 187 –92.
65. SARS and Public Policy Project Team, Governmental Emergency Response Capacity Building—Thoughts on
SARS Crisis (Public Policy Research Center of Northeastern Finance and Economics University, 2003).