- 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.)
 
 
 

1 comment:
less law more indie pop!
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