Commission on risk assessment (Cont.)

compare the risk of cancer and noncancer effects, such as "margin-of-

exposure" ratio which is currently used in a limited capacity by the

USEPA.

b. A second issue of concern is how risk assessments account for variations

in population exposure and susceptibility. The Commission recommends

distributional approaches (i.e., probabilistic risk assessment) to more

accurately address variations in exposure and susceptibility.

c. A third issue under debate is describing uncertainties associated with risk

assessments. The Commission highlights the importance of

communicating both quantitative and qualitative risk to risk managers.

The importance of focusing risk assessment on other forms of risk, such

as that associated with microorganisms and radiation, in addition to risk

posed by chemicals is also expressed.

The Commission proposes the involvement of stakeholders in the ecological

risk assessment process, as well as in human health risk assessment. It notes that

the current framework for conducting ecological risk assessments needs

supplemental guidance regarding the involvement of stakeholders in ecological

risk assessment.

The next section of the report addresses the use of cost analysis in conjunction

with risk assessment in regulatory decision-making. The Commission states that,

"Considering costs and benefits in regulatory decision-making can help to clarify

the tradeoffs and implications associated with alternative regulatory policies and

help regulatory agencies to set priorities." Two forms of cost analysis are

highlighted in this document. One is "cost-effectiveness analysis" which can help

choose an option which meets a specific regulatory goal for the least amount of

money. The second form of cost analysis is "benefit-cost analysis" which is used

to "assess the benefits and cost of different health-based standards with different

levels of health protection."

There is also a section of the Commission's report which discusses

communication and comparison of risk. The Commission stresses the fact that risk

assessors, risk managers, stakeholders, and the public all have different

perceptions of risk. However, risk assessment can help to reach a consensus

regarding priorities for environmental health and safety ("comparative-risk

ranking"). Also in their report, the Commission cautions risk assessors in the use

of "bright lines," "numerical values between unacceptable and negligible

magnitudes of risk or exposure concentrations of concern." "Bright lines" should

be used as goals for decision-making but should not be applied inflexibly. The

Commission further expresses its view on the importance of peer review in risk

assessment and that laws expanding judicial review to cases regarding agency

compliance with "detailed procedural requirements" or "the resolution of complex

scientific issues" should not be supported.

The next section of the document outlines current Federal agency risk

assessment and risk management practices. Also, within the USEPA,

recommendations are made for the incorporation of risk assessment methods to

Appendix A Summary of Federal, State, and Regional Guidance