National Institute of Environmental Health Sciences
In prior studies by high-level commissions, emphasis was given to improving the scientific basis and institutional procedures for risk assessment and risk regulation within existing statutory frameworks. Recommendations have led to slow but steady progress. This study is considerably different. It emphasizes a public health approach for efficient use of resources in a new flexible framework for risk management, reductionist approaches to risk assessment and characterization, increased public involvement, and various methods for managing such public involvement. It provides a mix of aspirations and concepts, procedures, and "shop floor rules" for putting the new system of risk management into practice. Concerns remain, however, that bright lines and other rules are at odds with the report's professed aspirations for meaningful public involvement; that ad hoc institutional arrangements for putting each risk in a situational context may not be an efficient use of public and private resources; that techniques for managing stakeholder involvement will be seen as manipulative and may even increase public mistrust and anxieties about risk; and that reductionism by the regulatory clients of risk assessment could diminish progress in the environmental health sciences. Says Lucier, "The goal of risk assessment should be to prevent environmentally or occupationally mediated diseases or injury. This point is not made sufficiently clear in the commission's report. Nevertheless, the report does an admirable job of attempting to merge science, common sense, public perception, public health, economics, and stakeholder interests into a regulatory policy strategy." He continues, "The merging of these diverse inputs will never be easy and should never be overly prescriptive. The complete integration of all relevant information into the risk assessment and risk management process will require greater reliance on expert judgment to make decisions that are timely, that are based on appropriate peer review, that are consistent with public health priorities, that do not create unnecessary regulatory burdens, and that are understandable by the public." The commission's report provides an alternative vision of risk management that incorporates popular political and social trends. Thorough evaluation of the report's recommendations will, at the very least, focus scrutiny on current risk assessment and risk management practices and perhaps produce better solutions.
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