In defined benefit plans, less risk is picking assets that track the liabilities. This typically means long-term government bonds. If you had a pension plan in 2008 and it was all in long-term government bonds, you were fully funded at the beginning of the year and you were fully funded at the end of the year.
But here's the problem. You can tell pension plans to go down that road. The next thing I look at is what kind of return they are going to get on long-term government bonds and the answer right now is 4%.