US Risk Assessment Policy: A History of Deception

US Risk Assessment Policy: A History of Deception
A Response to Arden Rowell, Allocating Pollution, 79 U Chi L Rev 985 (2012)
Edward J. Calabrese† INTRODUCTION
Strategies to limit the general public’s exposure to toxic substances— via national standards such as community-based drinking water and air quality standards, food residue regulations, hazardous-waste siting deci- sions, or other strategies—are based on multiple factors including social, political, cultural, historical, economic, technological, as well as public health–related concerns. At the core of these decisions is the need for risk assessment estimates to be based on a sound foundation, using scientifical- ly validated procedures and having high reliability. However, while it may be hard to believe, and even more difficult to accept, the foundation of our fundamental dose-response model—that is, the threshold dose-response— upon which all public health standards were originally based, and upon which we still highly depend, was never validated by the regulatory and scientific communities prior to its adoption by the FDA, EPA, OSHA, and other agencies in the United States and elsewhere in the world.https://lawreview.uchicago.edu/sites/lawreview.uchicago.edu/files/uploads/Dialogue/Calabrese%20Online.pdf