Echoing concerns raised by scientists, consumer groups and agency heads, the council — part of the congressionally chartered National Academies — told the OMB to limit itself to outlining guiding principles and leave details to experts in the nation’s scientific agencies.
Interesting concept, letting experts handle the specialized work. Doing that would allow regulators to take special account of populations like children and pregnant women, and would also allow regulators to prevent harm, not just respond to it.
This is apparently the first time in NRC history that they have rejected a proposed policy wholesale.
The report notes that the bulletin proposing new rules misdefines risk assessment (the topic of the report) and “the goals [proposed for risk assessment] mostly emphasize efficiency, rather than quality, in the conduct of risk assessment. Thus, the goals do not all support the primary purpose of the bulletin – ‘to enhance the technical quality and objectivity of risk assessments.’ ”
The bulletin also failed to adequately address scientific measures of uncertainty. This is one of the trickiest concepts for non-specialists to grasp in general, and there is variation in how uncertainty is evaluated in different fields. The report observes “in the absence of clear guidance regarding the conduct of uncertainty analysis, there is a serious danger that agencies will produce ranges of meaningless and confusing risk estimates, which could result in risk assessments of reduced rather than enhanced quality and objectivity.”
The bulletin also omits discussion of ecological risks, engineering risks, and technological risks. Since these standards are meant to be applied throughout the government, including to ecological, engineering and technological problems, that is obviously problematic.
The report goes on to note “the most glaring omission,” no criteria for assessing the benefits to be gained from implementing the bulletin. The bulletin implies that agencies do not currently meet the proposed standards, but doesn’t actually establish what standards agencies are applying, or how well they do so.
In short, the report is an attempt to water down and complicate the process for assessing risk.