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This ignores a fundamental public health goal to control exposures well before they cause functional impairment.

 
Scientific Review of the Proposed Risk Assessment Bulletin from the Office
of Management and Budget
http://www8.nationalacademies.org/onpinews/newsitem.aspx?RecordID=11811

Date:  Jan. 11, 2007
Contacts:  Bill Kearney, Director of Media Relations
Michelle Strikowsky, Media Relations Assistant
Office of News and Public Information
202-334-2138; e-mail <news@nas.edu>

FOR IMMEDIATE RELEASE

Report Recommends Withdrawal of OMB Risk Assessment Bulletin

WASHINGTON -- A draft bulletin issued by the White House Office of
Management and Budget prescribing technical standards for federal risk
assessments is "fundamentally flawed" and should be withdrawn, according
to a new National Research Council report.

Risk assessments are often used by the federal government to estimate the
risk the public may face from such things as exposure to a chemical or the
potential failure of an engineered structure, and they underlie many
regulatory decisions.  Last January OMB issued the draft bulletin, which
included a new definition of risk assessment and proposed standards aimed
at improving federal risk assessments.  OMB also requested that the
Research Council review the bulletin.

"We began our review of the draft bulletin thinking we would only be
recommending changes, but the more we dug into it, the more we realized
that from a scientific and technical standpoint, it should be withdrawn
altogether," said John F. Ahearne, chair of the committee that wrote the
report, and director, ethics program, Sigma Xi, The Scientific Research
Society, Research Triangle Park, N.C.

The committee agreed with OMB that there is room for improvement in
federal risk assessments and that additional guidance would help.
However, it concluded that the bulletin would not accomplish its stated
goal of enhancing the technical quality and objectivity of federal risk
assessments.  OMB should instead issue a different type of bulletin that
outlines goals and general principles for risk assessments, but that
directs federal agencies to develop their own technical guidelines to meet
those goals and principles.  "The new bulletin should draw on the risk
assessment expertise that exists in federal agencies and the organizations
that advise them," Ahearne said.

Although the general thrust of the draft bulletin appears to be consistent
with past expert recommendations on risk assessments, a number of specific
proposals are inconsistent, the committee said.  It added that the
bulletin attempts to move standards for risk assessment into "territory
beyond what previous reports have recommended and beyond the current state
of the science."  Also, OMB's definition of risk assessment is too broad
and in conflict with long-established concepts and practices.

Many of the standards proposed in the bulletin are unclear, the report
adds.  In particular, OMB's proposal of separate standards for general
risk assessments and "influential" ones is problematic because agencies
may not know at the outset whether a risk assessment will be considered
influential.  The committee also took issue with the bulletin's definition
of an adverse health effect because it implies that only clinically
apparent effects should be considered adverse.  This ignores a fundamental
public health goal to control exposures well before they cause functional
impairment.

The bulletin also omits several topics, further limiting its usefulness,
the committee said.  For example, OMB erred in focusing mainly on human
health risk assessments while neglecting risk assessments of technology
and engineered structures.  The bulletin's incomplete and unbalanced
approach to engineering, ecological, and other types of risk assessments
contradicts its stated objective of improving the quality of risk
assessment throughout the federal government, the committee added.  The
bulletin also gives little attention to the integral role of risk
communication, the importance of default assumptions in conducting risk
assessments, and the risks faced by sensitive populations, such as
children and pregnant women.

OMB has not established a baseline of each agency's proficiency at
conducting risk assessments, nor estimated the cost of implementing the
bulletin.  However, the committee determined -- based on comments from the
agencies and its own knowledge of risk assessment practices -- that some
aspects of the bulletin's implementation could be beneficial but that the
costs are likely to be substantial.  Overall, the committee concluded that
the potential for negative impacts on the practice of risk assessment in
the federal government would be very high.

The committee noted that risk assessment is not a monolithic process or
single method, adding that "one size does not fit all."  However, it
recommended that federal agencies addressing similar risks should work
together to develop common technical guidance, helping to ensure
appropriate consistency in federal risk assessment practices.  The
technical guidance should be peer reviewed and include procedures for
ensuring compliance.  Although OMB should determine whether the technical
guidance fully addresses the risk assessment principles OMB outlines,
development and peer review of the guidance should be left to the
agencies, the report states.

OMB requested the Research Council report, and it was sponsored by the
U.S. Environmental Protection Agency; U.S. departments of Agriculture,
Defense, Energy, Health and Human Services, and Labor; and NASA.  The
National Academy of Sciences, National Academy of Engineering, Institute
of Medicine, and National Research Council make up the National Academies.
They are private, nonprofit institutions that provide science,
technology, and health policy advice under a congressional charter.  The
National Research Council is the principal operating agency of the
National Academy of Sciences and the National Academy of Engineering.  A
committee roster follows.

Copies of Scientific Review of the Proposed Risk Assessment Bulletin from
the Office of Management and Budget will be available from the National
Academies Press; tel. 202-334-3313 or 1-800-624-6242 or on the Internet at
http://www.nap.edu. ; Reporters may obtain a pre-publication copy from the
Office of News and Public Information (contacts listed above).

Scientific Review of the Proposed Risk Assessment Bulletin from the Office
of Management and Budget $62.75 324 pages paperback Washington DC:
National Academies Press. 1-800-624-6242 The National Academies Press
500 Fifth Street NW
Lockbox 285
Washington, DC 20055