and available data before selecting defaults. The committee struggled with what the current policy means in terms of both literal interpretation and application to the risk-assessment process. The lack of clarity has the potential to lead to multiple interpretations. It raised questions regarding the implications of the policy for risk decision-making. It is difficult to argue with a more robust examination of available science, which the committee strongly supports; however, the committee expressed concern that without clear guidelines on the extent to which science should be evaluated, the open-ended approach could lead to delays and undermine the credibility of defaults and the ultimate decision process. The committee notes that the risk-characterization handbook (EPA 2000a) provides some statements regarding the need to identify key data gaps and avoid delays in the risk-assessment process in the planning and scoping phase, but it is concerned that such statements may not be adequate to address complications resulting from the current policy:
Another discussion during the planning and scoping process concerns the identification of key data gaps and thoughts about how to fill the information needs. For example, can you fill the information needs in the near-term using existing data, in the mid-term by conducting tests with currently available test methods to provide data on the agents(s) of interest, and over the long-term to develop better, more realistic understandings of exposure and effects, and to construct more realistic test methods to evaluate agents of concern? In keeping with [transparency, clarity, consistency, and reasonableness] TCCR, care must be taken not to set the risk assessment up for failure by delaying environmental decisions until more research is done (p. 29).
The policy may be appealing at first glance: it creates a two-phase process that obligates the agency to give full attention to all available and relevant scientific information and in the absence of some needed information to use defaults rather than allow uncertainties to force an end to an assessment and to related regulatory decision-making. On closer examination, the current policy carries a number of disadvantages.
Depending on implementation, the position in the current policy as articulated in the 2004 staff paper (EPA 2004a) and 2005 cancer guidelines (EPA 2005a) could represent a radical departure from previous policies. Rather than starting with a default that represents a culmination of a thorough examination of “all the relevant and available scientific information,” this policy has the potential to promote with each assessment a full ad hoc examination of data and the spectrum of inferences they may support without being selective or contrasting them with the default to reflect on their plausibility. There are then no real defaults, and every inference is subject to ready replacement. By definition, a full evaluation of the evidence identifies the best available assumption, whether it is based on chemical-specific information or more general information. Thus, EPA takes on, even more than before, the burden of establishing that existing science does not warrant use of an inference different from the default. There is also the commitment “to examine all relevant and available data” first. Pushed to the extreme for some chemicals, that can mean retrieving, cataloging, and demonstrating full consideration of thousands of references, many of little utility but nonetheless “relevant.” It also could lead to the reopening of the basis of some of the generic defaults on an ad hoc basis, as discussed below. Those possibilities create further vulnerability to challenge and delay that could affect environmental protection and public health. From a practical management perspective, the mandate to consider “all relevant and available data” may be unworkable for an overburdened and underresourced EPA (EPA SAB 2006, 2007) that is struggling to keep up with demands for analysis of hazard and dose-response