Coming to terms with acceptable risk
By John P Dyver and Paolo E Ricci
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Curtis Travis and Holly Hattemer-Frey have proposed a new approach to setting administrative exposure standards for hazardous chemicals ( I ) . Based on an earlier survey of 132 federal exposure standards for suspected carcinogens (2). they maintain it is possible to identify a “population-based de m n i festis” level of “acceptable risk” that could form the basis for future standard-setting decisions. According to the authors, this approach “would maintain consistency with past decisions and simplify regulatory decision making.” Certainly any proposal that promises to simplify standard-setting requires careful consideration. The seemingly endless administrative and judicial battles over the “proper” level of risk probably have done more harm than good by delaying the adoption of much needed standards. A reform that reduced the amount of time needed to issue standards but that still produced acceptable standards would be an important advance. It is important to understand the details of the Travis and Hattemer-Frey proposal before trying to evaluate its usefulness. First, they observe that for small populations federal agencies have barred exposures imposing individual lifetime risks above IO-’, and that that risk level drops to for larger p p u lations. In their words, “the existence of a population-based de manifestis level (or ceiling) in the range of IO-?to is a regulatory fact.” Thus they accept the actual as the normative. Second, Travis and Hattemer-Frey assert that regulators should not consider compliance or other societal costs of reducing risks to the proposed ceil0015936)(18910923-0145$01.5010
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