> Policy News -February 15, 2006
>
> OMB proposals aim to harmonize federal risk assessments
> New proposals urge federal risk assessors to move away from worst-case
> scenarios.
>
> On January 9, the White House Office of Management and Budget (OMB)
> released a draft bulletin outlining, for the first time, proposals on
> how federal regulatory agencies should assess the likelihood and
> severity of risks before they issue rules, policies, or
> recommendations.
>
> The draft proposals would apply to many controversial U.S. EPA risk
> assessments, such as the reference dose for the rocket-fuel
> contaminant perchlorate and national air quality standards. The new
> guidelines would also encompass EPA's Integrated Risk Information
> System data and the U.S. Food and Drug Administration's tolerances for
> food contaminants.
>
> The bulletin's proposals specify that independent analysts must be
> able to reproduce government assessments with the same data and
> models. The changes would also place more emphasis on scientific
> uncertainty and genetic variability and intensify the focus on
> "middle" estimates of risk-the most likely scenario for most
> people-rather than a worst-case scenario for small numbers of people.
> For low-dose-chemical risks, the bulletin asks federal agencies to
> make a stronger case that an actual adverse effect is observed and not
> just a subtle marker of exposure.
>
> The bulletin focuses on the technical aspects of risk assessment,
> rather than risk management or risk communication. OMB plans to
> finalize the guidelines later this year after a National Academy of
> Sciences review and public comment period, which ends on June 15.
>
> The proposals follow new guidelines for peer review, data quality, and
> cost-benefit analyses of regulations, which have been put forth since
> well-known risk assessment expert John Graham became the administrator
> of OMB's Office of Information and Regulatory Affairs five years ago.
>
> Public-health interest groups and advocates of government efficiency
> call this draft bulletin "significant". Former OMB official Jim Tozzi,
> who is now president of the conservative policy analysis group Center
> for Regulatory Effectiveness, says that the bulletin's recommendation
> will make it harder for agencies to make risks sound scarier than they
> really are. "Agencies will have to compare the risk they assess to a
> risk that is familiar to most people," he says. "[That] reduces an
> agency's flexibility to pick and choose to suit their agenda."
>
> But regulatory analyst Robert Shull with the liberal group OMB Watch
> calls the bulletin troubling. "It is also the latest element in a
> sequence of policy changes designed to undermine protective policies
> by shifting attention away from polluters and onto the regulatory
> protections themselves," he says.
>
> Experts also note that the bulletin defines "an adverse effect" as
> implying "some functional impairment or pathologic lesion that affects
> the performance of the whole organism or reduces an organism's ability
> to withstand or respond to additional environmental challenges." This
> significantly affects a determination crucial in risk analysis, says
> Harvard Center for Risk Analysis director James Hammitt. "Reference
> doses and other limits are often set on the 'most conservative' [i.e.,
> smallest] dose that shows an 'adverse effect' in laboratory animals,"
> he points out. "So defining what measurable effects count as adverse
> can be very important."
>
> But Andrew Maier, the assistant director for the nonprofit group
> Toxicology Excellence for Risk Assessment, says that this is an
> ongoing problem for all risk assessments. "We are getting better at
> understanding the biology, but that doesn't make it easier to
> understand the risk. Often, it is not as simple as, 'Yes, it does
> cause an adverse effect' or 'No, it doesn't,'" he says.
>
> Maier notes that most of the bulletin is consistent with evolving best
> practices in risk assessment, which present risk numbers along with
> upper and lower bounds. He adds that such an assessment is
> "intellectually honest" but that what's missing is guidance on how
> risk managers should use the range or interpret the number.
>
> -REBECCA RENNER

http://pubs.acs.org/subscribe/journals/esthag-w/2006/feb/policy/rr_OMBproposals.html