Clean Air Act Commission on Risk Assessment and Risk Management

Risk Assessment and Risk Management in Regulatory Decision- Making Draft Report for Public Review and Comment (June 13, 1996)

Under the Clean Air Act Amendments of 1990, a Commission on Risk Assessment and Risk Management was mandated "to make a full investigation of the policy implications and appropriate uses of risk assessment and risk management in regulatory programs..." After two years of meetings, the commission recently released its draft report for public comment.

Given the draft report, I think their investigation (or at least their reporting of it) was somewhat less than "full." Consider some of their more egregious statements (There are so many, I don't know where to begin!)

Radiating Disinformation. There is no doubt about the many serious health effects of exposure to ionizing radiation..., whereas the effects of many regulated chemicals are of uncertain importance for humans.

This is a comical statement given that no one on the commission is a radiation expert. With the exception of the increase in cancer risk associated with very high radiation exposures (e.g., atomic bomb survivors, underground uranium miners, and early radium watch dial painters) this statement is absolutely without basis. In fact, it is even becoming less politically incorrect to discuss the beneficial health effects of radiation exposure. The commission should review the Health Physics Society's (HPS) 1996 position statement on radiation exposure.

Hot Air. Compared with extensively regulated outdoor pollution, indoor air pollution can pose a substantial risk to human health.

I wonder how they know that! There's virtually no data (let alone reliable data) on the health effects of indoor air. This is best demonstrated by U.S. Occupational Safety and Health Administration's (OSHA) 1994 proposal to regulate workplace indoor air quality. OSHA proposed to regulate indoor air quality (at an OSHA-estimated annual cost of $8 billion) based on ONE survey of self-reported colds and headaches in 12 office buildings in San Francisco, California. TWELVE buildings? There are more than 4.5 MILLION indoor workplaces in the U.S.!

Where Old Wives' Tales Come From! ...specific indoor-air pollution problems have been identified or better appreciated over the past two decades. They include effects of environmental tobacco smoke, radon, asbestos, lead, and indoor allergens. Exposure to these pollutants is associated with clearly defined health effect, such as lung cancer and asthma.

Since I'm not aware of radon being associated with asthma, I must assume that the Commission believes indoor radon is associated with lung cancer. I wonder if the Commission still believes in the tooth fairy as well?

Also, the commission must have missed the Congressional Research Service's (CRS) 1995 analysis of the EPA risk assessment for environmental tobacco smoke (ETS). The CRS report basically concluded that the EPA ETS risk assessment was based on assumptions and policy, not science.

More Shameful Use of Children. ...Congress should also consider improvements to the existing safety standard [for pesticide residues in food.]... For example, the National Research Council (NRC) report "Pesticides in the Diets of Infants and Children concluded that the current tolerance-setting practices might not adequately protect children.

I think the absurdity of this statement is best demonstrated by Dr. Philip Landrigan, chairman of the committee that authored the NRC report. In a press interview following the report, even Landrigan (a card-carrying purveyor of junk science) acknowledged that no adverse health effects have ever been associated with the legal use of pesticides.

With "expert" panels like the commission, it's no wonder that junk science never goes away!

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