USE OF SCIENTIFIC RISK ASSESSMENT

Replacing so-called conservative methods now used by government agencies to assess risks with the best scientific estimates would lead to better decisions about reducing health risks from pollution, according to Dr. George Gray of the Harvard Center for Risk Analysis.

Risk assessment -- comparing and ranking risks -- plays a key role in such decisions as setting drinking water standards, cleanup goals at toxic waste sites and tolerances for pesticide residues in food. Better assessment is crucial for managing those risks in ways that ensure scarce public health resources are used wisely.

Annually, 2 percent of the gross national product of the United States is spent on environmental protection -- in ways that are chosen using risk assessments. According to Gray, the risks are assessed using faulty assumptions. Such inaccurate risk assessment distorts the benefit/cost analysis used to evaluate the effectiveness of regulations. Benefit/cost analysis means dividing the costs associated with a regulation or other intervention by the number of lives or years of life that may be saved. It varies widely among federal agencies. For example, the estimated median cost per life-year saved ranges from $23,000 for actions of the Federal Aviation Administration to $7.6 million per life-year saved for the Environmental Protection Agency.

To improve the process of assessing risks, Grey recommends requiring those assessing the risks to give the best estimates based on science. They should also give upper and lower bounds (values) for those risks, rather than single upper bound values that are misleading, and should use consistent methods so no particular risks are inflated in importance.

Source: George M. Gray, "Key Issues in Environmental Risk Comparisons: Removing Distortions and Insuring Fairness," May 1996, Policy Study No. 205, Reason Foundation, 3415 Sepulveda Blvd., Suite 400, Los Angeles, CA 90034, (310) 391-2245.

REPEAL THE RETROACTIVE LIABILITY PROVISION IN SUPERFUND

Superfund, the federal program created in 1980 to clean up hazardous waste sites, is largely viewed as a super failure. Critics say that the heart of the problem is its liability system -- in which fairness and justice play no part in determining who pays for cleanups.

Although President Clinton in his 1993 State of the Union message called Superfund a "disaster," the White House has so far balked at reforming the program and making it more fair -- for example, by repealing its retroactive liability provisions. Rep. Bill Zeliff (R-NH) has proposed a repeal of the retroactive provisions, but that reform is losing support in the House. Others contend Washington has no business cleaning up waste sites, which are essentially a state and local problem, and that responsibility should devolve back to these levels of government.

Source: Raymond J. Keating, "Superfund: Saved by Gridlock?" Investor's Business Daily, January 3, 1996.


REPEAL NEGLIGIBLE RISK STANDARDS

Talk about failure to apply cost-benefit analysis: the EPA is being forced to adhere strictly to an obsolete rule which will increase agricultural production costs - and consumer prices - more than $200 million per year.

At issue is the 1958 Delaney Clause, part of the Food, Drug and Cosmetic Act which prohibits any measurable residue found to cause cancer in animals or man in any processed foods. The Natural Resources Defense Council sued the EPA to enforce strict compliance and won. Crops most affected would be potatoes, apples and sugar cane - which face 55 percent of the total potential costs. Production costs are expected to increase $175 million this year, and $212 million per year after that. Because massive doses increase the risk of causing cancer in laboratory animals, half or more of all substances cause cancer in rodent Maximum Tolerated Dose tests.

Senator Richard Lugar (R-IN) has introduced a bill that would implement "negligible risk" standards and thus introduce some sanity into pure food regulations.

Source: Michael Fumento (Reason Magazine), "How Pure Must Food Be?" Investor's Business Daily, November 8, 1995.

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