December 11, 1995

EPA-SAB-EC-COM-96-002
The Honorable Carol Browner
Administrator
U.S. Environmental Agency
401 M Street, SW
Washington, DC 20460

      Subject:  Science Advisory Board Commentary on the Consideration of
           Results of Foreign Assessments

Dear Ms. Browner:

   The Science Advisory Board (SAB) reviews many Environmental Protection Agency
(EPA) reports.  Increasingly, other countries, especially in the European Union and Japan, prepare
sophisticated, high quality assessments of environmental risks which are also being evaluated by
EPA (e.g. contaminated river sediments, dioxin, etc.). While EPA reports often refer to data
resulting from foreign technical studies, they seldom refer to other countries' risk assessments.
We write to suggest that EPA's reports would be strengthened if they referred to the risk
assessment conclusions reached by other countries.

   In discussing this issue at our recent Executive Committee meeting, we learned of your
March 21, 1995 Risk Characterization Policy. While it does not specifically require that the
conclusions of risk assessments from foreign countries be mentioned in EPA documents, it does
indicate that risks estimated by EPA should "...be compared with past Agency decisions, (and)
decisions by other federal or state agencies...", where appropriate.

   We agree with this point and think that this policy regarding risk decisions might be
expanded to include comparisons with information gained from other countries' evaluations of
environmental risks.  This information would be quite useful to us when we evaluate EPA's
technical positions.
                 Sincerely,
                 Dr. Genevieve Matanoski, M.D., Chair
                 Science Advisory Board

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