Scientific Procedures in Regulatory Agencies

In Carl F. Cranor, Regulating Toxic Substances: A Philosophy of Science and the Law. New York, US: OUP Usa. pp. 103-151 (1993)
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Abstract

The chapter discusses some of the risk assessment issues that arise in administrative agencies charged with regulating carcinogens. It is argued that present assessment strategies, as well as some recommended by commentators, both of which are inspired by the paradigm of research science—the use of careful, detailed, science-intensive, substance-by-substance risk assessments—paralyze regulation. The identification, assessment, and regulation of potential carcinogens are all too slow to evaluate adequately the existing universe of 50,000–100,000 chemical substances, and the 1,000–1,500 new ones that are added each year. Thus, for identified carcinogens we need to adopt something like the expedited approximation procedures, which permit faster evaluation of potentially toxic substances. Alternative approaches to regulatory science which acknowledge and use normative considerations to guide assessment procedures and which recognize the importance of the rate of evaluation will expedite risk assessments and reduce regulatory false negatives and underregulation.

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