likely disruptive effect on many agencies of implementing the bulletin. Moreover, if some of the provisions discussed in earlier chapters and below were ultimately interpreted in a rigid one-size-fits-all way, the overall adverse impact would be substantially greater.
As a starting point, the committee addresses OMB’s failure to undertake—or at least provide to the public—an evaluation of the likely benefits and costs of implementing the bulletin for agency risk assessment practices and the consequences of that omission for the committee’s work.
OMB, the champion of benefit-cost analysis for decision-making, requires agencies that propose major regulations to provide quantitative, or at least qualitative, information regarding the anticipated consequences of their proposals. It was therefore surprising that OMB did not include such information in its proposed bulletin.
For example, to gauge the benefits to be achieved from implementing the bulletin, it is essential to specify the baseline—in this case, the agencies’ current practices with respect to risk assessment. Although OMB has implied that the agencies do not now meet the standards it seeks to establish, it has not constructed a baseline specifying risk assessment proficiency for each agency (or even each of the major regulatory agencies), including the extent to which a few, some, or many agencies produce generally satisfactory and high-quality risk assessments or the reasons why those or other agencies fall short of the specified standards. Specifically, OMB has not established which agencies do not know what good practices are and which agencies do not have the ability, resources, or incentives to meet those standards.
Similarly, OMB has not identified the costs that could be incurred by implementing the bulletin. The extent of the changes in the agencies will generally depend on the extent to which they are not currently meeting the standards set forth in the bulletin—again, a baseline issue. Beyond that, however, OMB has not identified the costs, such as the staff resources necessary to meet the bulletin’s standards, the additional time that would be required to meet the standards, and the disruption that would result from changing established practices. Nor has OMB indi-