- having internal inconsistencies,
- inappropriately suggesting separate risk assessment approaches for general v. "influential" assessments, given the difficulty of determining what assessment might be influential at the outset,
- having too limited an evaluation of what constitutes an "adverse health effect,"
- erroneously focusing on human health risk assessments while neglecting technological risk assessments,
- providing risk assessment standards that are "beyond the state of the science", and
- failing to address risk communication (as compared to the a proposal by the European Commission) and sensitive populations.
So OMB's plan is currently on hold. (Thanks to my research assistant VS, who forwarded this to me.)