By Amy
Charlene Reed, RiskWorld staff
E-mail to: reed@tec-com.com.
The final draft of a major report on the California Environmental
Protection Agency's chemical risk assessment practices
regarding human health was released November 18 on the Internet.
The report, A Review of the California Environmental Protection Agency's Risk Assessment Practices, Policies, and Guidelines, is on line at http://www.oehha.ca.gov/risk/raac/final.html.
Mandated by the state legislature and written by an external scientific committee -- the Risk Assessment Advisory Committee (RAAC) -- the report offers 11 recommendations for improvements in five main areas: uncertainty, variability and risk characterization; hazard identification; dose-response assessment; exposure assessment; and cross-cutting issues. Cross-cutting issues include the incorporation of new science into risk assessment practices, consistency with the methods and research of the U.S. Environmental Protection Agency, and the need for increased peer review.
"Risk assessors and managers in other states and in the federal agencies can benefit from what California has learned as a result of the report's findings," said the committee Chair James N. Seiber, who is director of the University of Nevada's Center for Environmental Sciences and Engineering in Reno, Nevada. "California got involved early on with risk assessment and has probably been doing risk assessment longer than any other state and almost as long as the federal government. The implementation of the report's recommendations will set a tone for other states."
He added that the California EPA welcomed the committee's constructive criticism and is expected to voluntarily implement most of the report's recommendations within the next 12 months. One reason for the agency's receptiveness is that Richard A. "Rick" Becker, who was recently appointed director of the California EPA's Office of Environmental Health Hazard Assessment, is a strong supporter of the committee's work.
"This situation could have been in a tug of war between the agency and the RAAC committee if agency officials had resented our criticisms and suggestions. But it wasn't that way at all," Seiber said. "The state has already set up a process for addressing every one of the report's recommendations and has asked members of the RAAC core committee to help with their plans for implementation."
While the report staunchly supports the use of risk assessment, describing it as a tool that "helps prevent arbitrary decisions by providing a systematic means of incorporating scientific information in decision-making," the committee noted weaknesses and perceived faults. "Risk assessment is known to have considerable uncertainty, and there are difficulties in applying this imperfect process to decision-making," states the report's executive summary. "Some are concerned that cancer is over-emphasized as a risk assessment endpoint, that the results of risk assessments are skewed on the side of health protection, placing unjustified economic burdens on California's industries, and that risk managers apply the results in an inflexible manner. Others, however, are concerned that the process serves as a means for risk assessors to control decision making, primarily to the benefit of industry."
A driving force that led the state legislature to mandate the report was industry's complaint that it is sometimes placed in the position of trying to conform to state environmental regulations that differ from federal regulations.
"[T]here appeared to be some cases of duplication of effort, where Cal/EPA conducted a risk assessment for a chemical for which U.S. EPA had recently completed a risk assessment. Such redundancies waste resources and may place the regulated industry in a real or perceived "double jeopardy" situation," the report's executive summary states.
As a result, the report's first recommendation is that the agency should take the lead in initiating steps to assure consistency and cooperation with U.S. EPA and other federal counterparts. Seiber emphasized that this recommendation doesn't mean the state should mirror the federal government in every case.
"The report doesn't advocate taking away California's ability to do its own risk assessments. Some situations are unique to California and require that risk assessments be tailored," Seiber said. "The important point is for the agency to justify its actions when it departs from the federal government's actions. That has not always been done in the past."
The report also recommends that the agency establish procedures to ensure that its risk assessment practices are consistent internally. Departments of the California EPA that conduct risk assessments include the Office of Environmental Health Hazard Assessment, the Department of Pesticide Regulation, the Department of Toxic Substances Control, the Air Resources Board, the California Integrated Waste Management Board, the State Water Resources Control Board, and the Regional Water Quality Control Boards.
Related Links
Members of the Risk Assessment Advisory Committee
RiskWorld's October 25, 1996, article "California EPA's Chemical Risk Assessment Report Now Due November 1"
California Environmental Protection Agency
California
EPA's Office of Environmental Health Hazard Assessment
Story posted on November 19, 1996; links updated January 17, 2002.
Copyright © 1996 by Tec-Com
Inc.