Distortions of the “Mis-Read” Book: Adding Procedural Botox to Paralysis by Analysis (original) (raw)

Http Dx Doi Org 10 1080 10807030390240337, 2010

Abstract

Twenty years after the publication of the National Research Council's report Risk Assessment in the Federal Government: Managing the Process, called the “Red Book,” we can call it the “mis-read” book, despite its great influence and frequent citation. The book is best remembered for the four-step paradigm for risk assessment, a useful matrix for analysis of the process of defining chemical exposure limits. However, the primary purpose of the study was to judge early proposals for adding “procedural botox” to the paralysis-by-analysis then slowing public health interventions against chemicals. Our Red Book Committee rejected that approach. Another recommendation, separating risk assessment from risk management, has also been misinterpreted. Unfortunately, the committee's long discussion of adding alternatives to default, consistent decision rules was cited to support elaboration of risk assessment by those who seek to obstruct public health protection. This strategy crystallized into legislation, most recently S. 691, which nearly passed the U.S. Senate in 2001. Since 1983, evidence for carcinogenicity of many exposures in the occupational environment has greatly proliferated, but public health protection has stagnated. Alternatives to default assumptions can be considered “Houdini Risk Assessment” hypotheses, which enable industry and regulatory agencies to make risks disappear and escape from the need to intervene. Houdini hypotheses include: peroxisome proliferation for phthalates; alpha2-microglobulin for petroleum hydrocarbons; lung overload hypothesis for particle carcinogenesis; and mouse clara cell tumors for methylene chloride among others. In contrast to the community environment, the occupational environment contains many exposures already shown to pose risks at exposures permitted by prevailing exposure limits.

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