change of the magnitude outlined in Chapter 8.1 As in all enterprises, funding is a rate-limiting and quality-determining step.

TRANSITION TO THE FRAMEWORK FOR RISK-BASED DECISION-MAKING

Improving the utility of risk assessment to include upfront problem formulation and scoping and planning with an expanded array of options requires several practical steps to ensure that risk assessors and risk managers have a clear understanding of their roles and responsibilities and have sufficient guidance to administer them effectively. As a beginning, EPA should examine the key functions and attributes of its decision-making processes in relation to those recommended in this report. Although many activities are comparable (for example, hazard assessment and dose-response assessment), others, such as life-cycle assessment, will be new in many agency programs and will need to be integrated into the process of assessing risks and the options for managing them.

Historically, even though EPA risk assessment is generally linked to decision-making, guidance arising out of National Research Council risk-assessment reports has been directed mainly to improving agency risk assessments with little attention to future decision-making. The framework focuses attention on improving the utility of risk assessments to better inform decision-making. To implement the framework, the agency will need innovative and instructive guidance that informs its scientists, economists, lawyers, regulatory staff, senior managers, and policy makers of their roles and, most important, fosters interaction among them. Principles, examples, and practices drawn from “success stories” in which EPA and other entities have used processes similar to those proposed for the framework offer starting points for such guidance. Selected risk-based decision-making scenarios that provide realistic illustrations of how the framework can work can be especially instructive.

The framework promotes greater attention to and use of risk-related information from such fields as economics, psychology, and sociology—disciplines not usually involved to a great extent in EPA assessments. While those fields may not be central in the risk assessment itself, the framework integrates a variety of information in constructing risk-management decisions. Increased emphasis on those fields in the framework requires extending the kind of robust peer-review practices historically required by statute or policy for risk assessment to cost and benefit analyses, community impact assessments, life-cycle analyses, and related information.2 The objective would be to give decision-makers, stakeholders, and the public confidence in, and understanding of, the insights and limitations of evaluations. Improved peer review of analyses will also add an important dimension of transparency.

INSTITUTIONAL PROCESSES

The framework presents opportunities for EPA to review and realign some institutional processes to foster consistent approaches to using risk assessment and other analyses (in-

1

This committee comment is prompted by recent congressional testimony on the impact of budget cuts on EPA’s capacity to meet the demands of risk assessment as currently practiced (Renner 2007). The budget cuts generate serious concern about the agency’s capacity to undertake the advanced analyses recommended in this report and to implement a new, more data-intensive framework without concerted attention to funding and staffing as part of governmentwide and EPA strategic planning and annual budget processes.

2

As in traditional risk assessment, peer reviewers would be experts in the discipline under review—sociologists for societal impacts, economists for economic impacts, and so on. However, especially valuable would be the addition of peer reviewers, expert in multiple disciplines, that can evaluate the risk and benefit-cost analyses that inform different decision options.



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