Risk Analysis and Cost-Benefit
Analysis of Environmental
Regulations

Linda-Jo Schierow
Analyst in Environmental Policy
Environment and Natural Resources Policy Division

December 2, 1994

94-961 ENR

CONTENTS FOR THE ENTIRE DOCUMENT

SUMMARY
INTRODUCTION
BACKGROUND
-- DEFINITIONS
-- RISK ANALYSIS AT EPA
-- -- Origin of Environmental Risk Analysis
-- -- Influence of Federal Guidelines on EPA Risk Analysis
-- -- State of the Art of Risk Analysis: EPA

-- RISK MANAGEMENT AT EPA
-- -- Comparative Risk Analysis at EPA
-- -- Economic Analysis
-- -- -- The Influence of Environmental Statutes
Ordering of Perceived Risk for 30 Activities and Technologies
Table 1. Statutory Authority for Considering Risks, Technological Capacity, and Costs in Developing Regulations
-- -- -- Statutes Requiring Analysis of Federal Regulations
-- -- -- President Reagan's Executive Orders (Now Revoked)
-- -- -- EPA's Response to the Reagan Orders
-- -- -- Regulatory Planning and Review in the Clinton Administration .

Table 2. Key provisions of President Reagan's Executive Orders 12291 and 12498,
now revoked, and President Clinton's Executive Orders 12866 and 12875
Table 3. Characteristics of "Major Rules" and "Significant Regulatory Actions"

ANALYSIS
-- ISSUES IN ENVIRONMENTAL RISK MANAGEMENT
-- -- How Valuable Is the Information Provided?
-- -- Is It a Scientific Basis for Environmental Decisions?
-- -- Should It Be Used to Quantify Environmental and Health Benefits?
-- -- Should Priorities Be Based on Relative Risks?
-- -- Would Additional Analysis Improve Risk Management?
-- THE INFORMATION VALUE OF RISK ANALYSIS
-- -- Key Factors Determining the Quality of Information Provided
-- -- Quality of the Database
-- -- Risk Assessment Methods
Some Subjective Judgements in Risk Assessment

LEGISLATIVE ACTIVITIES
-- LEGISLATION IN THE 103RD CONGRESS
-- OUTLOOK FOR THE 104TH CONGRESS

SELECTED REFERENCES

APPENDIX REQUIREMENTS FOR ANALYSIS OF RISKS, COSTS, AND BENEFITS IN SENATE-PASSED BILLS OF THE 103RD CONGRESS: A COMPARISON WITH REQUIREMENTS IN EXECUTIVE ORDERS OF PRESIDENTS REAGAN AND CLINTON

SUMMARY

Concerns about the national economy, environment, public health, and the quality of EPA's regulatory process have led Congress to consider proposals to require EPA analyses of risks, costs, and benefits of proposed regulations. Proponents of analysis want the results used to design more efficient regulations and to prioritize environmental problems for Federal attention. Risk analysis summarizes available scientific information about hazardous activities, chemicals, or technologies and the effects they may have on exposed animals or people under various conditions, for example, with or without regulation. Risk and economic analyses can be qualitative or, if information is sufficient, quantitative, but economists can only quantify economic benefits of enviromental regulations if scientists can quantitatively estimate risks to health and the environment.

Economic analysis and risk analysis of many management options already are required by executive order and statute; EPA has conducted such analyses for 20 years. The quality of its analyses and the influence of the results on management decisions have been both praised and criticized. Some environmental statutes prevent EPA from using analytic results in developing regulations .

Prospects are high that the 104th Congress will consider legislative proposals to promote EPA risk and economic analyses. Five general questions are at issue: 1) How valuable is the information provided by risk analysis for policymakers? 2) Is risk analysis a scientific basis for environmental decisions? 3) Should risk analysis be used to quantify environmental and health benefits? 4) Should priorities be based on relative risks? and 5) Given that EPA already analyzes risks, costs, and benefits, would additional requirements for analysis improve risk management? People generally agree that risk analysis is valuable for summarizing scientific information, but disagree about its scientific objectivity and information value for environmental policymakers, because risk is only one aspect of environmental problems. Also, the quality of information provided by risk analysis depends heavily on the quality of available data, which varies, so that the results of risk analysis almost always are debatable.

Some general legislative approaches include: 1) authorizing or requiring EPA to analyze regulations, 2) authorizing or requiring EPA to consider costs and/or risks in making regulatory decisions, 3) requiring reports to Congress on the results of regulatory analyses, 4) authorizing funding for analysis, 5) requiring research and development of analytic methods, the database, or guidelines for risk assessment, 6) establishing guidelines for risk assessment or presentation of results, and 7) requiring peer review. An appended comparison of analytic requirements in key legislative proposals and executive orders finds President Clinton's order to be most comprehensive.

INTRODUCTION

Many Governors, Mayors, Members of Congress, and others are concerned about the high cost of compliance with environmental regulations. In particular, some believe EPA has promulgated requirements that achieve small increments in environmental quality or human health protection without adequately considering the economic costs of those decisions. They argue that the resources consumed in promulgating, enforcing, and complying with such regulations could better protect public health and the environment if they were more commensurate with the risks potentially avoided by regulation and were directed to controlling environmental hazards posing greater risks. Therefore, many support legislation requiring risk analysis of environmental problems and economic analysis of EPA regulations. EPA supporters argue that EPA has analyzed risks, costs, and benefits for major regulations and most other significant decisions for more than a decade. However, many of the Agency's decisions are driven by specific statutory mandates, discussed below, that may limit EPA's regulatory flexibility or its ability to consider cost when developing regulations. Other risk management decisions are driven by ambiguous legislative language which EPA cautiously interprets for various reasons, including uncertainty about health risks and lawsuits from environmental groups. Congress establishes priorities for EPA's regulatory activities when it mandates deadlines for issuance of regulations in environmental legislation and authorizes or appropriates funds for specific programs. According to some sources, EPA has little discretionary authority to choose targets for regulations based on risks.(1)

Various legislative proposals in the 103rd Congress addressed the issue of how EPA should manage risks. Some would have required EPA to conduct formal economic analyses of existing and proposed environmental regulations and forego regulation when costs exceed quantifiable benefits. Others would have had EPA evaluate regulations and their alternatives based on the magnitude of risk potentially controlled by each option. Still others would have required EPA analysis of the relative magnitude of risks addressed by its regulations. More modest proposals would have established an office of environmental risk within EPA or mandated research to improve the quality of risk analysis or communication of the results. Prospects are high that the 104th Congress will continue to debate these proposals.

This report describes and analyzes the issues and legislative options related to risk analysis and risk management at EPA and considers the potential impact of proposed legislation on EPA's rule-making process and final regulations. The report begins by defining some key terms used in the discussion and by providing: background information on EPA's historical use of risk and economic analyses; provisions of existing law that authorize, mandate, or constrain the use of the results of risk analysis and economic analysis by EPA; and various studies of EPA's risk analysis and economic analysis policies and practices. The second major section of the report summarizes and analyzes proposals, issues, and legislative options. The report concludes with a brief summary of the legislative activities in the 103rd Congress and a list of selected references. (For more information about specific proposed legislation, see CRS Issue Brief IB 94036, The Role of Risk Analysis and Risk Management in Environmental Protection and the CRS Report Comparison of Environmental Risk Provisions in the 103rd Congress, 94-716 ENR.)

The Environment and Natural Resources Policy Division of CRS conducted an advanced workshop on cost-benefit-risk analysis of proposed EPA regulations on July 19, 1993. Guest speakers who presented five perspectives were: John Graham, Professor and Director, Harvard Center for Risk Analysis, Harvard School of Public Health; James D. Wilson, Regulatory Issues Director, Monsanto Company, and President, Society for Risk Analysis; Erik Olson, Senior Attorney, Natural Resources Defense Council, and former EPA employee; Adam Finkel, Fellow, Center for Risk Management, Resources for the Future; and Richard D. Morgenstern, Director, Office of Policy Analysis, Office of Policy, Planning, and Evaluation, U.S. EPA. The purpose of the workshop was to examine areas of agreement and disagreement among panelists regarding the advantages and disadvantages of increased use of cost-benefit-risk analysis of EPA regulations. Drs. Graham and Wilson spoke in favor of, and Mr. Olson spoke against, an increased role for cost-benefit-risk analysis at EPA. Dr. Finkel provided arguments both for and against an increased role for cost-benefit-risk analysis at EPA. Dr. Morgenstern discussed the legal, fiscal, and practical considerations that affect EPA's use of cost-benefit-risk analysis. The speakers' presentations, answers to follow-up questions, and participation in an open discussion with the moderator and audience provided valuable information that is referenced throughout the analytic section of the report.

BACKGROUND

DEFINITIONS

Experts in risk analysis disagree about how "risk" and related terms should be defined. For the purpose of this discussion, however, the following definitions have been adopted. "Environmental risk" is defined as the probability of occurrence of a particular adverse effect on human health or the environment as a result of exposure to an environmental hazard; an "environmental hazard" may be a hazardous chemical in the environment, a natural hazard, or a hazardous technology (for example, a dam).

"Environmental risk assessment" refers to any formal or informal scientific procedure used to produce a quantitative estimate of environmental risk. For example, risk assessment is often used to estimate the expected rate of illness or death in a human population ex-posed to a hazardous chemical based on the number of experimental animals affected by various doses of the chemical as measured in laboratory experiments.(2) "Environmental risk analysis" is defined more broadly to include any quantitative or qualitative scientific description of an environmental hazard, the potential adverse effects of exposure, the risks of these effects, events and conditions that may lead to or modify adverse effects, populations or environments that influence or experience adverse effects, and uncertainties with regard to any of these factors (3) Generally, risk analyses are based on scientists' evaluations of results of scientific research, extrapolations of these results to predict the type and to estimate the extent of effects in exposed populations, and judgments about the number and characteristics of persons exposed to hazards at various levels. The final step in risk analysis is "risk characterization," which summarizes scientific judgments about the existence and overall magnitude (that is, the incidence) of adverse effects given specified levels of exposure to a hazard.

The Four Steps of Risk Analysis

hazard identification: determining whether a particular chemical causes a particular health effect

dose-response assessment: determining the relationship between magnitude of exposure and probability the health effect will occur

exposure assessment: determining the extent of exposure before or after application of regulatory controls

risk characterization: describing the nature and often the magnitude of risk, including attendant uncertainty

"Risk management" is the process of deciding what should be done about a hazard, the population exposed, or adverse effects, implementing the decision, and evaluating the results. Decision makers may consider social, political, economic, legal, ethical, and engineering information as well as scientific risk estimates in choosing among available risk management options. Comparative risk analysis and economic analyses use the results of environmental risk assessments but are risk management activities, conducted to inform decisions about management options. Risk management decisions often require value judgments on such questions as 'What level of risk is acceptable?" and "What level of expenditure is reasonable?" Another aspect of risk management is "risk communication" which includes any information exchange about a hazard or risk.

A "comparative risk analysis" evaluates a number of environmental hazards relative to one another and assigns to each a priority, based on one or more characteristics of the individual hazards. Often ranks are based on the relative magnitude of risk, which presupposes that a quantitative environmental risk assessment has been conducted for each hazard. A comparative risk analysis may group hazards, for example, as "high," "medium," or "low" risks, or arrange them in rank order. Alternatively, hazards may be evaluated based on the amount of risk that may be avoided using available technologies and resources. This is often referred to as ranking according to "risk reduction opportunities."

"Economic analysis" refers to any systematic procedure to evaluate real or anticipated resource expenditures and losses (costs) relative to real or anticipated gains (benefits). "Cost-benefit-risk assessment" is the quantification and monetary valuation of the expenditures, gains, and losses, and the calculation of net benefits to society associated with the adoption of a particular regulation (or alternative management strategy) to address an environmental hazard. Quantitative environmental risk analysis (that is, risk assessment) is a necessary prerequisite to the conduct of cost-benefit-risk assessment of environmental regulations, because the " benefits" are the risks avoided (that is, the adverse effects on human health or the environment, or risks of such effects, that the regulation is meant to address.) Risk assessment may be used to estimate the number of people or animals likely to be harmed by exposure to the hazard under each regulatory strategy, including a "do-nothing-different" strategy that reflects the current policy, or regulation, or laissez faire. Benefits may be expressed in such terms as numbers of lives saved or illnesses or species extinctions avoided. Risk that is expected to remain after a new regulation is implemented may be subtracted from the risk under current conditions to estimate risk reduction opportunities -- that is, the "expected benefit " -- of each regulatory alternative. If benefits are translated into monetary terms to allow cost-benefit-risk assessment, various techniques may be used to calculate the dollar values of health effects; these values may be derived from studies of how much people are willing to pay to avoid exposure to a hazard or particular adverse effect, or based on savings of direct costs, such as health care expenditures, salary loss for the duration of an illness, or the years of work lost to premature death. The intent is to estimate the gross monetary value of benefits to society, rather than to individuals. "Net benefit" is the expected monetary benefit less the cost of implementing the regulation.

RISK ANALYSIS AT EPA

Origin of Environmental Risk Analysis

Most of the major environmental protection statutes have provisions that require, or have been interpreted by EPA to require, decisions about the amount of pollution or potentially polluting activity that is considered to be "safe." To inform such decisions, EPA began soon after it was formed in 1970 to systemat-ically collect and analyze data to describe and evaluate environmental conditions and trends. EPA's earliest efforts to evaluate environmental data, however, were frustrated by the difficulty of defining "good" environmental quality; scientists could not agree on a definition. They readily agreed, however, that the environment should not be hazardous to human health or ecosystems. Therefore, EPA began to focus efforts on defining risks.

Procedures for analyzing hazards and measuring risks existed prior to 1970, but had been developed for purposes other than environmental protection (for example, to determine life insurance rates or the likelihood of flooding) and had not been widely applied to more complex environmental hazards. Because EPA urgently needed suitable tools to carry out its mission, it supported the development of the newly consolidated field of risk analysis and helped to found the Society for Risk Analysis (4) The Agency was among the first to apply the methods of risk analysis to problems in environmental protection. EPA developed new procedures and adapted methods from such disciplines as sanitary and industrial engineering, psychology, economics, sociology, statistics, and operations research. By the mid 1970s, EPA was conducting risk analyses to support some of its decisions.

Influence of Federal Guidelines on EPA Risk Analysis

Other Federal agencies with responsibilities for protecting human health and safety, such as the Food and Drug Administration (FDA) and the Occupational Safety and Health Administration (OSHA), also were conducting risk analyses by the mid 1970s. Each agency independently developed analytic procedures suitable for its mission, authority, and budget; published results of risk assessments; and, designed risk management activities with reference to scientists' risk estimates. However, because agencies often shared jurisdiction over an industry or chemical and sometimes came to different conclusions about the level of risk associated with chemicals or industries, as well as the level of risk that should be regulated (a risk management decision), some independent investigators and industry scientists were of the opinion that certain Federal scientific risk assessments were of poor scientific quality. They criticized the Federal Government for allowing inconsistent analyses of risks.(5) Often criticisms targeted EPA which tended to produce higher risk estimates and to regulate more stringently.

These criticisms of Federal risk analyses focussed on the diverse choices made by different agencies to cope with inherent uncertainties of risk analysis that arise from missing or ambiguous information on hazards and gaps in current scientific theory. Although generally characterized as a scientific activity, risk analysis is not, and probably can never be, entirely objective or fact-based. Risk analysis was developed to evaluate what is known about things that cannot be known with certainty. Thus, risk analysis produces an estimate, never an exact prediction, of the magnitude and severity of risk. (Weather forecasts, for example, are risk estimates.) Environmental risk analysis is especially beset by many uncertainties, because data usually are sparse, and scientific theories explaining hazards, exposures, and effects often have not been established. To conduct a risk analysis under these conditions, requires choices among plausible alternative assumptions and competing theories to bridge the gaps. Because these choices cannot be based on science alone, they are subject to challenge. For example, if data are available for two animal species, which data should an analyst use or how should data be combined to estimate risk to a third species? The National Academy of Sciences (NAS) identified 50 choices beyond the realm of science (so-called "inference choices") that affect risk analyses.(6) For an excellent, though somewhat dated, discussion of inference choices in the context of cancer risk analysis, see chapter two in Making Cancer Policy by Mark Rushefsky.(7)

In 1977, the EPA, OSHA, the Consumer Product Safety Commission (CPSC), and FDA responded to the criticisms of risk analyses by establishing an Interagency Regulatory Liaison Group (IRLG) to coordinate procedures forn analyzing cancer risks.(8) The Food Safety and Quality Service of the U.S. Department of Agriculture (USDA) joined the IRLG soon thereafter. The IRLG proposed in 1979 a general "cancer policy" to coordinate risk analysis and risk management across agencies to the extent permitted by statute. According to the NAS, this was "the first evidence that all the [F]ederal regulatory agencies agreed on the inference options applicable to the identification of carcinogenic hazards and measurement of risks".(9)

However, the IRLG policy was controversial. Some scientists and industrial and environmental groups accused the Carter Administration of allowing policy prescriptions to influence scientific judgments. In response, Congress authorized a study by the NAS on institutional arrangements that might improve the agencies' use of risk analysis.(10)

The NAS published the results of the study in a 1983 landmark report, Risk Assessment in the Federal Government: Managing the Process, also known as "The Red Book." It described the risk analysis policies and practices of all Federal agencies and concluded that no change in institutional structure was necessary or desirable to improve risk assessments. In addition, the Academy provided a general framework for cancer risk assessment that still is used today; recommended that agencies separate risk assessment from risk management; and suggested development of uniform general risk assessment guidelines for the Federal Government.

In 1985, the NAS framework was adopted by the White House Office of Science and Technology Policy (OSTP), which included scientists from the regulatory agencies, the National Institutes of Health, and other Federal agencies. Although the OSTP decision was not binding on the agencies' risk analysis practices, it provided a consistent basis for developing agency guidelines.

The Reagan and Bush Administrations convened numerous interagency meetings, conducted studies, and issued guidance in the hope that uniform policies and procedures might be established to guide risk analysis and management in the Federal Government. However, no formal guidelines materialized. In August 1994, an interagency work group for the Clinton Administration released Draft Principles for Risk Assessment, Management, and Communication to serve as a "general policy framework" for implementing regulatory policy.

Many argue that interagency guidelines cannot, or should not, be established, because the different missions and objectives of Federal agencies require them to adopt different approaches to analyzing and managing risks. Others claim that such guidelines are undesirable because they might freeze development of risk analysis at an immature stage, when its procedures are still rapidly evolving. Still others favor adoption of formal guidance because it would make the decision-making process more transparent to outside observers and, they argue, reduce the influence of politics on scientific judgments made during risk analyses.

In response to criticisms and calls for consistent risk analyses, EPA became in 1977 the first Federal agency to propose interim guidelines for its cancer risk assessments. In 1986, it was the first agency to establish final guidelines for analyzing risks of cancer and other health effects, all of which were based on the 1983 NAS framework (51 Federal Register 33992-34054, Sept. 24, 1986). In addition to cancer risks, the 1986 guidelines for analysis addressed: the risk that a chemical will cause mutations affecting future generations or damage to human development (developmental risks); human exposure to individual chemicals; and human health risks of chemical mixtures. The Agency revised its guidelines for developmental risks in 1991 and for exposure in 1992 (56 Federal Register 63798-63826, Dec. 5, 1991; 57 Federal Register 22888-22938, May 29, 1992).

In recent years, EPA has continued to be "the main player in developing and revising risk assessment guidelines ... [O]nly EPA has completed scientific reviews of some of its guidelines and formally modified them in response to new scientific information," according to the Congressional Office of Technology Assessment.(11) EPA's cancer risk assessment guidelines currently are being revised. In addition, guidelines currently are being developed for analyzing neurotoxicity and reproductive risks and for exposure measurements. The Agency has proposed a rough framework for ecological risk analysis based on recommendations of the NAS.(12)

State of the Art of Risk Analysis: EPA

Concerns about the scientific quality of risk analyses by Federal agencies have generated numerous studies, often at the request of Congress. A 1987 Office of Technology Assessment comprehensive study of agency policies for animal carcinogenicity studies and for identifying, assessing, and regulating carcinogens concluded:

Both risk assessment and risk management incorporate policy choices and reflect the values of the risk assessors and managers. Some agencies have attempted to establish separate staffs for the two tasks, but this separation does not eliminate the need to make policy choices about the assumptions used in risk assessments.

The values and policy preferences of decision-makers, risk assessors, and representatives of industry, labor unions, environmental organizations, and public interest groups often differ. Scientists disagree about the nature of scientific evidence. These differences explain some of the past controversies over the regulation of specific carcinogenic chemicals and the development of agency policies.

... Adoption of general guidelines cannot resolve these specific disputes. (13)

Responding to a mandate in the Clean Air Act Amendments of 1990, the NAS National Research Council assessed the current state of EPA risk analyses. The 1994 NAS report Science and Judgment in Risk Assessment concluded:

• EPA should generally retain its conservative approach to risk assessment (in which the Agency makes judgments that err, if necessary, on the side of public safety) in the initial phase of setting standards, but EPA should more clearly state its principles.
• EPA should develop and use an iterative approach to risk assessment, beginning with relatively inexpensive screening techniques and moving on to more resource-intensive levels of data gathering, model construction, and model application as each situation warrants. At each level, risk should be reevaluated to produce a more precise estimate. Iteration should cease when no further refinement of the risk estimate is needed to inform risk managers.
• EPA should work to continually improve the models and data used in risk assessments and develop a standard procedure for deviating from its conservative approach to risk assessment when warranted by scientific considerations.
• "Risk assessment is a set of tools, not an end in itself. The limited resources available should be spent to generate information that helps risk managers to choose the best possible course of action among the available options" (p. E-14).

The Clean Air Act Amendments of 1990 also established a Risk Assessment and Management Commission to consider the NAS report, methods for measuring and describing risks of chronic human health effects from exposure to hazardous substances, methods to reflect uncertainties, and risk management policy issues. The Commission also was directed to comment on the possibility of developing a consistent risk assessment methodology, or standard of acceptable risk, among various Federal programs.

Members of this Commission have been appointed and the first meeting was held May 16, 1994.(14) At this meeting it was agreed that the Commission would address the contentious issues surrounding proposed legislation requiring risk analysis and Executive Order 12866 on regulatory review (discussed below). The Commission is about two years behind the schedule set by Congress, and hopes to issue its final report in March 1996.

Endnotes

l For example, Dan Beardsley, former EPA official with the Office of International Activities, as quoted in: Roberts, L. "Counting on Science at EPA." Science, v. 249, August 10, 1990. p. 618.

2 Laboratory studies of toxicity are supervised and interpreted by toxicologists. Epidemiologists, who also contribute data for risk assessment, study the health of human populations who have been exposed, usually accidentally or occupationally, to a hazard.

3 Others might use these terms differently. The important point is that it is necessary to distinguish between an analysis that focuses exclusively on the numbers associated with a hazard and a broader analysis that also considers such qualitative features as the dread a hazard inspires or the irreversibility of harm. A similar distinction is drawn between "economic analysis" and "cost-benefit-risk assessment" below.

4 The Society for Risk Analysis is an international organization of professionals with a strong interest in risk analysis. The membership is multidisciplinary including toxicologists, epidemiologists, statisticians, chemists, physicists, political scientists, economists, psychologists, journalists, sociologists, policy analysts, public affairs specialists, and educators. Researchers, practitioners, and users of risk analysis attend the annual meeting to present papers and learn about the latest risk research.

5 Environmentalists also criticized EPA's risk assessments, but their complaint was that EPA used risk assessment to justify less rigorous enforcement of environmental statutes.

6 National Academy of Sciences. Risk Assessment in the Federal Government: Managing the Process. Washington, D.C., National Academy Press. 1983. pp. 29-33.

7 Rushefsky, Mark E. Making Cancer Policy. New York, State University of New York Press, 1986, p. 37-54.

8 The IRLG was disbanded in 1981.

9 NAS. Ibid. p. 61.

10 The study was authorized in the Act making appropriations for Agriculture, Rural Development, and Related Agencies programs for the fiscal year ending September 30, 1981 (P. L. 96-528). The study was carried out by the National Research Council with support from the Food and Drug Administration.

11 U.S. Congress Office of Technology Assessment. Researching Health Risks Washington, U.S. Govt. Print. Off. 1993. p. 120.

12 U.S . EPA, Risk Assessment Forum. Framework for Ecological Risk Assessment. EPA/630/R-92/001. Washington, U.S. Environmental Protection Agency, February 1992. 41 p.

13 U.S. EPA, Risk Assessment Forum. Report on the Ecological Risk Assessment Guidelines Strategic Planning Workshop. EPA/630/R-92/002. Washington, U.S. Environmental Protection Agency, February 1992. 57 p.

U.S. EPA, Risk Assessment Forum. Draft Ecological Risk Assessment: Issue Papers. EPjV630/R-94/004A. September 1993. 544 p.

13 U S Congress. Of fice of Technology Assessment. Identifying and Regulating Carcinogens: Background Paper. OTA-BP-H-42. Washington, U.S. Govt. Print. Off., November 1987. p. 5.

14 The ten members of the Commission are: Barbara Bankoff (appointed by President Bush), Peter Y. Chiu and Alan Craig Kessler (appointed by President Clinton), David P. Rall and Norman Anderson i appointed by the Majority Leader of the Senate), Gilbert Omenn and Joshua Lederberg (appointed by the Speaker of the House), Virginia Weldon (appointed by the Minority Leader of the House), John Doull (appointed by the Minority Leader of the Senate), and Bernard Goldstein (appointed by the President of the National Academy of Sciences).