Commission on risk assessment (Cont.)

1990 to "make a full investigation of the policy implications and appropriate uses

of risk assessment and risk management in regulatory programs under various

federal laws to prevent cancer and other chronic human health effects which may

result from exposure to hazardous substances."

This document makes several recommendations which have direct implications

for the Corps of Engineers DMMP. They are:

a. The Clean Water Act should be amended to establish a comprehensive,

integrated watershed-management approach that uses ecological risk

assessment and biotic-integrity measurements to provide for the

development of state watershed programs.

b. The USEPA and the states should continue to use receiving water quality

and risk assessment to set priorities for water pollution control programs,

and risk assessment should be used to establish water quality criteria and

effluent limits (with the caution that risk assessment, and especially

ecological risk assessment, should not yet be used to supplant technology-

based and quality-based techniques).

c. The public should be involved in the risk-based decision-making process

note that this is consistent with the public coordination process already

used in dredged material management.

d. Risk assessment should be in conjunction with a cost benefit analysis as

part of the decision making process.

e. Risk assessments should be cautious regarding the use of "bright lines" or

numerical criteria.

Summary: This document strongly recommends that risk assessment be

incorporated into Federal regulatory decision-making within and among Federal

agencies. It emphasizes the involvement of stakeholders in risk assessment and

risk management. Also in this report, the Commission presents its vision of a risk

management framework, discusses the uses and limitations of risk assessment and

of economic analysis, and makes specific recommendations for the use of risk

assessment in Federal regulatory agencies and programs.

The philosophy of the Commission regarding risk management and risk

assessment is that the problem or concern should be formulated in a broad

context. They comment that risk analysis is often based on the effects of

individual chemicals on human or environmental receptors. The Commission calls

for the risk assessor to consider how mixtures of chemicals may act in various

media to cause "chronic health effects." They also state that the focus of risk

analysis should be to protect public health and the environment by considering

realistic scenarios and scientific methods.

The report also discusses three risk assessment issues currently under debate:

a. One of the issues discussed is the assessment of toxicity and relevance to

humans. The Commission suggests that a common metric is needed to

Appendix A Summary of Federal, State, and Regional Guidance