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be served by the preparation and release of a report on the science-policy issues and decisions that affect EPA's risk-assessment and risk-management practices.

Comparisons of Risk

EPA often does not elucidate all relevant considerations of technical accuracy when it compares and ranks risks.

EPA should further develop its methods for risk comparison, taking account of such factors as differing degrees of uncertainty and of conservatism in different categories of risk assessment.

Policy Focus on Stationary Sources

Title III focuses primarily on outdoor stationary sources of hazardous air pollutants and does not consider indoor or mobile sources of those pollutants.

EPA should clearly communicate to Congress that emissions and exposure, and thus the aggregate risk to the public, related to indoor and mobile sources might well be higher than those related to stationary sources.

Risk Management and Research

EPA does not appear to use risk assessment adequately as a guide to research and might abandon some important risk-assessment and regulatory efforts prematurely because of data inadequacies.

The conduct of risk assessment reveals major scientific uncertainties in a highly systematic way, so it is an excellent guide to the development of research programs to improve knowledge of risk. EPA should, therefore, not abandon risk assessments when data are inadequate, but should seek to explore the implications for research. Risk-assessment uncertainties can also help to determine the urgency with which such research should be developed. In particular, improved cooperation between EPA's Office of Air Quality Planning and Standards (OAQPS) and its Office of Research and Development (ORD) through such actions as joint publication of a research agenda on hazardous air pollutants would be most helpful.



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