Risk Assessment of Environmental Chemicals: If It Ain't Broke …

In this commentary, I argue that just because the Environmental Protection Agency (EPA) could improve chemical risk assessment methodology is not sufficient reason that it should improve chemical risk assessment methodology. My particular concern is that many of the repeated efforts to reform risk assessment for chemical risks impair the ability to use what has been a reasonably effective tool for risk management and lose sight of public health and environmental objectives. Adages related to fixing items that are not broken include the classic: “If it ain’t broke don’t fix it,” usually ascribed to Bert Lance, the somewhat unsavory chief of staff of President Jimmy Carter.(1) Colin Powell has stated the opposite: “‘If it ain’t broke, don’t fix it’ is the slogan of the complacent, the arrogant or the scared. It’s an excuse for inaction, a call to non-arms.”(2) While personally sympathetic to Powell’s position, a third formulation, attributed to the journalist Dell Hunt (2001), is probably most apropos to this commentary: “If it ain’t broke . . . the government will fix it until it is” (Dell Hunt, 2001).(3) My concern is the apparent willingness of much of the risk science community to aid and abet the government’s propensity to fix what is not demonstrably broken. To make this point, I will briefly consider facets of standard low-dose chemical risk assessment, which are best treated as not fixable, but manageable: namely, the present inability to scientifically verify