Risk
Commission Completes Work,
Issues Three Final Papers
The Presidential/Congressional Commission on Risk Assessment and Risk Management, which was mandated as part of the Clean Air Act Amendments of 1990, disbanded on August 31, completing three years of work that began in 1994. The Commission, charged with making "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," issued two comprehensive reports early in 1997, both of which are published in RiskWorld.
Before disbanding, the Commission also issued three final papers: (1) Report on the Accomplishments of the Commission on Risk Assessment and Risk Management, (2) A Public Health Approach to Environmental Protection, and (3) Memorandum Regarding Tribal Risk Issues. These papers, each published in RiskWorld, are summarized below.
Report on the Accomplishments of the Commission on Risk Assessment and Risk Management
Commission Chair Gil Omenn summarizes the work of the Commission and explains that it chose to focus on creating a framework for environmental health risk management because the overriding process of risk management had not been examined systematically, whereas numerous reports and agency initiatives had already addressed risk assessment. The resulting framework included six steps with stakeholders involved in each.
Omenn lists specific accomplishments of the Commission, citing in particular the impact its work has had on policies of the Environmental Protection Agency, on the Food Quality Protection Act and the Safe Drinking Water Act Amendments of 1996, and on standards for risk management being developed by the American Society for Testing and Materials.
In reviewing the Commission’s work, Omenn said they adopted several positions: (1) a commitment to a multi-media, multi-source, multi-agent, and multi-risk context for analysis and decisions; (2) the recognition that there are other crucial elements in decision making in addition to scientific investigations and evaluations, (3) the determination to sustain the gains achieved in the last 25 years in environmental and health protection, and (4) a decision to develop program-specific recommendations for certain agencies.
The most important program-specific recommendations dealt with Section 112 of the Clean Air Act, the origin of the Commission’s mandate. The Commission presented a tiered approach to the assessment of residual emissions and risk after Maximum Achievable Control Technology requirements are implemented during this decade. In presenting this approach, the Commission illustrated the context, stakeholder, margin-of-exposure, and comparative risk principles that are key to its overall recommendations, calling for emissions and risk from a single source or sentinel chemical to be put into the context of all sources of those chemicals in its geographic area.
On another air pollution issue, the Commission highlighted the discrepancy between extensively regulated outdoor air pollution and indoor air pollution, which receives little attention and remains largely unregulated. In response, EPA has formed an Indoor Air Committee.
As a general matter, the Commission also stressed the practical value of expressing risks in terms of risk reduction, rather than fighting about abstruse estimates of absolute risk levels and the attendant methods for estimating the uncertainties in the estimates of risk levels.
Printed copies of Volume I (Framework for Environmental Health Risk Management) and Volume II (Risk Assessment and Risk Management in Regulatory Decision-Making) of the Commission’s final report may be obtained from the Government Printing Office at 202-512-1800: Volume I for $6.00 (stock number 055-000-00567-2, order form) and Volume II for $19.00 (stock number 055-000-00568-1, order form).
Volume I is being translated into Japanese and will be available from Secretariate of Mediation Committee for Environment Affairs, Sourifu Kougaitou Chousei-iinkai, 1-6-1 Nagata-chou, Chiyoda-ku Tokyo, Japan.
Symposium on a Public Health Approach to Environmental Health Risk Management
On August 8, 1997, the Commission on Risk Assessment and Risk Management convened a symposium with invited participants to address the need for and nature of a public health approach to environmental health protection and to explore the idea of "an environmental health improvement market."
Two panels were convened, the first charged with (1) defining a public health approach to environmental protection, clarifying its advantages and disadvantages, and (2) identifying legal, social, and cultural barriers to and changes required for the adoption of a public health approach.
The second panel addressed the possibility of setting up a public health improvement market in which investments would be made as regulatory tradeoffs, using the recent ozone and particulate air quality standards as an example.
The panels’ conclusions included the following:
(1) A firmer base in public health principles and practices is necessary for effective control of current and future environmental threats.
(2) Public health professionals have generally failed to understand their responsibilities and opportunities in the area of environmental health.
(3) A holistic approach including physical, social, and cultural aspects is central to a public health approach to the environment.
(4) Primary prevention, particularly in vulnerable populations, is important, but additional data, including mode of action and mechanistic data, are clearly needed to develop a risk-based approach for primary prevention.
(5) Achieving sustainability will require the development of environmental indicators that accurately reflect common goals.
(6) A public health investment market is possible, but public support and involvement will be necessary for it to function. Tradeoffs should focus on trading among environmental health risks and not between environmental health risks and other public health risks. Trades also must be contemporary, in the same geographic areas, and respectful of equity across population groups and tribal nations.
(7) The lack of environmental health involvement in the current restructuring of the nation’s electric power industry to minimize consumer rates is likely to pose environmental health risks.
Memorandum Regarding Tribal Risk Issues
As a result of its interactions with Native American risk assessors and others involved in tribal risk issues, the Commission on Risk Assessment and Risk Management makes the following recommendation to agencies involved in activities that address contamination impacting tribal lands:
An arrangement between Indian tribes and relevant United States Federal agencies should be established in order to define how agencies will assist tribes to develop tribal-specific risk assessment and risk management strategies. Such arrangements should be based on respect, equity, and empowerment in order to achieve the shared goals of restoring, protecting, and enhancing all aspects of the environment. Such arrangements are not intended to limit the discretionary powers of the agencies or of the Indian tribes.
Posted October 9, 1997
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