When it rains, it pours: the same day the White House closed the comment period on its proposed bulletin to govern agency guidance practices, the White House Office of Management and Budget released a proposed bulletin to govern agency risk assessments.

OMB's Office of Information and Regulatory Affairs (OIRA) released the Proposed Risk Assessment Bulletin on Jan. 9. It will be peer-reviewed by the National Academies of the Sciences and open to public comment through June 15.

OMB Watch will make more information and analysis available at www.ombwatch.org/regs/whitehouse/risk going forward. For now, here are some of the highlights of the bulletin:

• It calls on agencies to apply, where feasible, the risk assessment standards of the Safe Drinking Water Act.

   

• It gestures in the direction of risk/risk comparison, calling on agencies to write introductions that put the risks they are assessing in the context of other risks with which the public is familiar. Before becoming OIRA administrator, John Graham vigorously advocated a concept of risk/risk tradeoffs as a means of characterizing regulatory policy as irrational. With this approach, Graham once downplayed health risks associated with dioxin, the primary toxin found in Agent Orange, as "on par with other risks."

   

• The bulletin would apply heightened standards to "influential risk assessments," a new category that parallels the influential information category from OMB's peer review guidelines. New standards would include "substantial[] reproduc[ibility]," comparison against non-agency risk assessments, more emphasis on uncertainty and central tendency in risk ranges, formal response to "significant" comments, incorporating scientific disputes over the adverse or non-adverse nature of human health effects, and more.

Many of the issues now at stake in the risk assessment bulletin were discussed back in 2001 in an insightful report from Public Citizen called Safeguards at Risk. Published when John Graham was nominated to head OIRA, the report tracks the relationship of corporate special interest money and the cottage industry of aggressive manipulations of the discourse of risk toward anti-regulatory ends.