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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                        WASHINGTON D C 20460'
                            FEB 26 1992
                                                 LIBRARY, AWBERC, CINCINNATI
                                                       U. S. EPA
                                                 26 W. MARTIN LUTHER KING DRIVE
                                                   CINCINNATI. OHSCb 45268 >'
MEMORANDUM
SUBJECT:
FROM:
TO:
             Guidance on Risk Characterization  for Risk Managers
             and Risk Assessors

             F. Henry Habicht I
             Deputy Administrate
             Assistant Administrators
             Regional Administrators
                                               JBRARY, AWBERC, CINCINNAT.
                                                     U. S. EPA
                                              26 W. MARTIN LUTHER KING DRIVE
                                                 CINCINNATI. OHIO 45268
                           INTRODUCTION
     This memorandum provides guidance for managers and assessors
on describing  risk assessment results in EPA reports,
presentations,  and decision packages.  The guidance addresses a
problem that affects public perception regarding the reliability
of EPA's scientific assessments and related regulatory decisions.
EPA has talented scientists,  and public confidence in the quality
of our scientific output will be enhanced by our visible
interaction with peer scientists and thorough presentation of
risk assessments and underlying scientific data.

     Specifically, although a great deal of careful analysis and
scientific judgment goes into the development of EPA risk
assessments, significant information is often omitted as the
results of the assessment are passed along in the decision-ciaki.-.g
process.  Often, when risk information is presented to the
ultimate decision-maker and to the public, the results have been
boiled down to a point estimate of risk.  Such "short hand"
approaches to  risk assessment do not fully convey the range of
information considered and used in developing the assessment.   In
short, informative risk characterization clarifies the scientific
basis for EPA  decisions, while numbers alone do not give a true
picture of the assessment.

     This problem is not EPA's alone.  Agency contractors,
industry, environmental groups, and other participants in the
overall regulatory process use similar "short hand" approaches.

     We must do everything we can to ensure that critical
information from each stage of the risk assessment is
communicated from risk assessors to their managers, from middle

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to upper management, from EPA to the public, and from others to
EPA.  The Risk Assessment Council considered this problem over
many months and reached several conclusions:  1) We need to
present a full and complete picture of risk, including a
statement of confidence about data and methods used to develop
the assessment; 2) we need to provide a basis for greater
consistency and comparability in risk assessments across Agency
programs; and 3) professional scientific judgment plays an
important role in the overall statement of risk.  The Council
also concluded that Agency-wide guidance would be useful.


                            BACKGROUND

     Principles emphasized during Risk Assessment Council
discussions are summarized below and detailed in the attached
Appendix.

     Full Characterization of Risk

     EPA decisions are based in part on risk assessment, a
technical analysis of scientific information on existing and
projected risks to human health and the environment.  As
practiced at EPA, the risk assessment process depends on many
different kinds of scientific data (6.3., exposure, toxicity,
epidemiology), all of which are used to "characterize" the
expected risk to human health or the environment.  Informed use
of reliable scientific data from many different sources is a
central feature of the risk assessment process.

     Highly reliable data are available for many aspects of an
assessment.  However, scientific uncertainty is a fact of life
for the risk assessment process as a whole.  As a result, agency
managers make decisions using scientific assessments that are
less certain than the ideal.  The issues, then, become when ia
scientific confidence sufficient to use the assessment for
decision-making, and how should the assessment be used?  In or^er
to make these decisions, managers need to understand the
strengths and the limitations of the assessment.

     On this point, the guidance emphasizes that informed EPA
risk assessors and managers need to be completely candid about
confidence and uncertainties in describing risks and in
explaining regulatory decisions.  Specifically, the Agency's  risk
assessment guidelines call for full and open discussion of
uncertainties in the body of each EPA risk assessment, including
prominent display of critical uncertainties in the risk
characterization.  Numerical risk estimates should always be
accompanied by descriptive information carefully selected to
ensure an objective and balanced characterization of risk in  risk
assessment reports and regulatory documents.

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     Scientists call for fully characterizing risk  not  to
question the validity of the assessment,  but to fully inform
others about critical information in the  assessment.  The
emphasis on "full" and "complete" characterization  does not refer
to an ideal assessment in which risk is completely  defined by
fully satisfactory scientific data.   Rather, the concept of
complete risk characterization means that information that is
needed for informed evaluation and use of the assessment is
carefully highlighted.  Thus, even though risk characterization
details limitations in an assessment, a balanced discussion of
reliable conclusions and related uncertainties enhances, rather
than detracts/ from the overall credibility of each assessment.

     This guidance is not new.  Rather, it re-states, clarifies,
and expands upon current risk assessment  concepts and practices,
and emphasizes aspects of the process that are often incompletely
developed.  It articulates principles that have long guided
experienced risk assessors and well-informed risk managers,  who
recognize that risk is best described not as a classification or
single number, but as a composite of information from many
different sources, each with varying degrees of scientific
certainty.

     Comparability and Consistency

     The Council's second finding, on the need for greater
comparability, arose for several reasons.  One was confusion --
for example, many people did not understand that a risk estimate
of 10~6 for an "average" individual  should not be compared to
another 10~6 risk estimate for the "most  exposed individual".
Use of such apparently similar estimates  without further
explanation leads to misunderstandings about the relative
significance of risks and the protectiveness of risk reduction
actions.  Another catalyst for change was the SAB's report,
Reducing Risk:  Setting Priorities and Strategies for
Environmental Protection.  In order to implement the SAB's
recommendation that we target our efforts to achieve the greatest
risk reduction, we need common measures of  risk.

     EPA's newly revised Exposure Assessment Guidelines provide
standard descriptors of exposure and risk.  Use of these terms in
all Agency risk assessments will promote consistency and
comparability.  Use of several descriptors, rather than a single
descriptor, will enable us to present a more complete  picture  of
risk that corresponds to the range of different exposure
conditions encountered by various populations exposed  to most
environmental chemicals.

     Professional Judgment

     The call for more extensive characterization of risk has
obvious limits.  For example, the risk characterization includes

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only the most significant data and uncertainties from the
assessment  (those that define and explain the main risk
conclusions) so that decision-makers and the public are not
overwhelmed by valid but secondary information.

     The degree to which confidence and uncertainty are addressed
depends largely on the scope of the assessment and available
resources.  When special circumstances (e.g.., lack of data,
extremely complex situations, resource limitations, statutory
deadlines) preclude a full assessment, such circumstances should
be explained.  For example, an emergency telephone inquiry does
not require a full written risk assessment, but the caller must
be told that EPA comments are based on a "back-of-the-envelope"
calculation and, like other preliminary or simple calculations,
cannot be regarded as a risk assessment.


                       GUIDANCE PRINCIPLES

     Guidance principles for developing, describing, and using
EPA risk assessments are set forth in the Appendix.  Some of
these principles focus on differences between risk assessment and
risk management, with emphasis on differences in the information
content of each process.  Other principles describe information
expected in EPA risk assessments to the extent practicable,
emphasizing that discussion of both data and confidence in the
data are essential features of a complete risk assessment.
Comments on each principle appear in the Appendix; more detailed
guidance is available in EPA's risk assessment guidelines  (e.g.,
51 Federal Register 33992-34054, 24 September 1986).

     Like EPA's risk assessment guidelines, this guidance applies
to the development, evaluation, and description of Agency risk
assessments for use in regulatory decision-making.  This
memorandum does not give guidance on the use of completed risk
assessments for risk management decisions, nor does it address
the use of non-scientific considerations (e.g., economic or
societal factors) that are considered along with the risk
assessment in risk management and decision-making.  While  some
aspects of this guidance focus on cancer risk assessment,  the
guidance applies generally to human health effects  (e.g..,
neurotoxicity, developmental toxicity) and, with appropriate
modifications, should be used in all health risk assessments.
Guidance specifically for ecological risk assessment is under
development.


                          TMPLgMEHTATIQlf

     Effective immediately, it will be Agency policy for  each  EPA
office to provide several kinds of risk assessment  information in
connection with new Agency reports, presentations,  and decision

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packages.  In general, such information should be presented  as
carefully selected highlights from the overall assessment.   In
this regard, common sense regarding information needed to  fully
inform Agency decision-makers is the best guide for determining
the information to be highlighted in decision packages and
briefings.

     1.   Regarding the interface between risk assessment  and
          risk management, risk assessment information must  be
          clearly presented, separate from any non-scientific
          risk management considerations.  Discussion of risk
          management options should follow, based on
          consideration of all relevant factors, scientific  and
          non-scientific.

     2.   Regarding risk characterization, key scientific
          information on data and methods (e.g., use of animal  or
          human data for extrapolating from high to low doses,
          use of pharmacokinetics data) must be highlighted.  We
          also expect a statement of confidence in the assessment
          that identifies all major uncertainties along with
          comment on their influence on the assessment,
          consistent with guidance in the attached Appendix.

     3.   Regarding exposure and risk characterization, it is
          Agency policy to present information on the range of
          exposures derived from exposure scenarios and on the
          use of multiple risk-descriptors (i.e., central
          tendency, high end of individual risk, population risk,
          important subgroups, if known) consistent with
          terminology in the attached Appendix and Agency
          guidelines.

     This guidance applies to all Agency offices.  It applies tc
assessments generated by EPA staff and to those generated by
contractors for EPA's use.  I believe adherence to this Agency-
wide guidance will improve understanding of Agency risk
assessments, lead to more informed decisions, and heighten the
credibility of both assessments and decisions.

     From this time forward, presentations, reports, and decision
packages from all Agency offices should characterize risk and
related uncertainties as described here.  Please be prepared to
identify and discuss with me any program-specific modifications
that may be appropriate.  However, we do not expect risk
assessment documents that are close to completion to be
rewritten.  Although this is internal guidance that applies
directly to assessments developed under EPA auspices, I also
encourage Agency staff to use these principles as guidance in
evaluating assessments submitted to EPA from other sources, and
in discussing these submissions with me and with the
Administrator.

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     This guidance is intended for both management and technical
staff.  Please distribute this document to those who develop or
review assessments and to your managers who use them to implement
Agency programs.  Also, I encourage you to discuss the principles
outlined here with your staff, particularly in briefings on
particular assessments.

     In addition, I expect that the Risk Assessment Council will
endorse new guidance on Agency-wide approaches to risk
characterization now being developed in the Risk Assessment Forum
for EPA's risk assessment guidelines, and that the Agency and the
Council will augment that guidance as needed.

     The Administrator and I believe that this effort is very
important.  It furthers our goals of rigor and candor in the
preparation, presentation, and use of EPA risk assessments.  The
tasks outlined above may require extra effort from you, your
managers, and your technical staff, but they are critical to full
implementation of these principles.  We are most grateful for the
hard work of your representatives on the RAC and other staff in
pulling this document together.  I appreciate your cooperation in
this important area of science policy, and look forward to our
discussions.

Attachment

cc:  The Administrator
     Risk Assessment Council

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   GUIDANCE  FOR RISK  ASSESSMENT



Section 1.  Risk Assessment-Risk Management
            Interface

Section 2.  Risk Characterization

Section 3.  Exposure and Risk Descriptors
U.S. Environmental Protection Agency
       Risk Assessment Council
           November, 1991

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             1.  RISK ASSESSMENT  - RISK MAHAGEMENT

     Recognizing that for many people the term risk assessment

    wide meaning, the National Research Council's 1983 report on

risk assessment in the  federal government (hereafter

report") distinguished  between risk assessment and risk

management.

          Broader uses  of the      [risk assessment] than ours
          also embrace  analysis of perceived risks,
          comparisons of risks associated with different
          regulatory strategies,     occasionally analysis
          of     economic     social implications of
          regulatory decisions —
          t^__risk_manaaement  (emphasis added). (1)

In 1984, EPA endorsed these distinctions between risk

    risk management for Agency use (2),     later relied on

in'developing risk            guidelines (3),

     This distinction suggests that EPA participants in the

        can be grouped  into two main categories, each with

         different responsibilities, based on their roles with

        to risk assessment     risk management.

   "  *

          One group           the risk assessment by collecting,
          analyzing, and synthesizing scientific data to produce
          the hazard identification, dose-response,
          assessment portion  of the risk assessment     to
          characterize  risk*  This group relies in part on Agency
          risk assessment guidelines to address science policy
          issues     scientific uncertainties.

          Generally, this group includes scientists
          statisticians in the Office of Research
          Development,  the Office of Pesticides     Toxic
          Substances     other         offices-, the Carcinogen
          Risk Assessment Verification Endeavor (CRAVE),
          RfD/RfC Workgroups.

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          Others iase analyses produced by the first group to
          generate site- or media-specific exposure assessments
          and risk characterizations for use In regulation
          development.  These assessors rely on existing
          databases (e.g., IRIS, ORD Health Assessment Documents,
                and R£D/R£C Workgroup documents) to develop
          regulations and evaluate alternatives.

          Generally, this group Includes scientists     analysts
          in program offices, regional offices, and the Office of1
          Research     Development.

          Risk__Managenient

          A third group integrates the risk characterization with
          other non-scientific considerations specified in
          applicable statutes to make and justify regulatory
          decisions.

          Generally, this group includes Agency managers
          decision-makers.

Each group has different responsibilities for observing

distinction between risk assessment     risk management.  At

     time, the risk assessment process involves regular

interaction between each of the groups, with overlapping

responsibilities at various stages In the overall process.

         guidance to follow outlines principles specific for

          generate, review, use,     Integrate risk assessments

for decision-making*

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     1. ^Risk assessors     risk managers should b€ s«nsitiv® to
distinctions b«tw««n risk assessment and risk management.

     The major participants In the risk assessment process have

            responsibilities.  Where responsibilities differ, It

Is important that participants confine themselves to tasks In

            of responsibility     not inadvertently obscure

differences between risk assessment and risk management.

     J hared responsibilities of assessors     managers Include

Initial decisions regarding the planning     conduct of an

assessment, discussions as the assessment develops, decisions

                          to complete an assessment     to

        significant uncertainties.  At critical junctures In

assessment, such consultations       the nature of,     schedule

for,     assessment.

     For the                               distinguishing between-

                    'risk                  that scientific

information Is selected, evaluated,     presented without

considering non-scientific factors Including how     scientific

analysis might Influence     regulatory decision.  Assessors

        with  (1) generating a credible, objective," realistic,

         analysis;  (2)  presenting information on hazard, dose-

response,  exposure      risk;      (3) explaining confidence In

      assessment by  clearly delineating uncertainties

assumptions along with  the         of these factors (e.g.,

confidence limits,  use  of conservatlve/non-conservatlve

assumptions)  on the overall assessment.  They do not

decisions  on  the  acceptability 'of any risk level for protecting

                                 4

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public, health or selecting procedures for reducing risks.
     For itlJ2|Ls__oJLj^^                                    who
Integrate these assessments into regulatory decisions, the
distinction between risk assessment     risk management
refraining      Influencing     risk description through
consideration of non~scientific factors -- e.g., the regulatory
        ~          attempting to       the risk assessment to
      statutory constraints,      regulatory objectives, or
political purposes.  Such management considerations     often
           considerations for the overall regulatory decision
          principle), bat they have no role In estimating or
           risk.
     However, decision-makers establish policy directions that
          the overall nature          of Agency risk
     as-appropriate, provide policy guidance on difficult
controversial                       .               as risk
           priorities,        of conservatism,     acceptability
of particular risk levels     reserved for decision-makers who
            with making decisions regarding protection of public
health.

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     2.  Tfa« risk assessment product, that is, the risk
characterization, Is only on® of several kinds of Information
used for regulatory decision-making.
     Risk characterization, the last step In risk assessment, Is
the starting point for risk management considerations     the
foundation for regulatory decision-making, but It Is only     of
several Important components in such decisions.  Each of
environmental laws administered by EPA calls for consideration of
non-scientific factors at various stages In the regulatory
process*  As authorized by different statutes, decision-makers
evaluate technical feasibility (e.g., treatability, detection
limits), economic, social, political,     legal factors as
of     analysis of whether or not to regulate and, If so, to what
extent.  Thus, regulatory decisions are usually based on a
combination of     technical analysis      to develop     risk
               information from other fields.
     For this reason, risk               managers should
           that     regulatory decision is usually
solely by     -outcome of     risk assessment.  That is, the  '
analysis of     overall regulatory problem may     be          as
the picture presented by the risk analysis alone.  For example, a
pesticide risk assessment may describe          risk to
populations but, if the agricultural benefits of its use
important for the nation'a food supply,     product may be
allowed to remain on            with certain restrictions on
to        possible exposure.  Similarly, assessment efforts may
        an RfD for a particular chemical, but other

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considerations may result In a regulatory level that is more or
     protective than the RfD Itself,
     For decision-makers, this means that societal considerations
(e.g., costs, benefits) that, along with the risk assessment,
          regulatory decision should be described as fully as the
scientific Information     forth In the risk characterization.
Information on                  analyses, their strengths
limitations,            In     assessment* uncertainties,
alternative analyses     as Important      as they         the
scientific components of     regulatory decision.  Decision-
       should be able to expect, for «3tampie, the      level of
                        analysis as they receive from     risk
analysis.
     Decision-makers     not "captives of     numbers."  On
contrary,     quantitative     qualitative risk characterization
Is only one.of      Important factors that      be considered In
             final decision — a difficult     distinctly
different task'     risk                se«  Risk
          Involve numerous assumptions     uncertainties--
          technology,                      factors, which      to
be explicitly  identified         decIsion-makers         public.

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                        2.  RISK CHARACTERIZATION
     EPA risk assessment principles and practices draw on many
sources.  The environmental laws administered by EPA, the
National Research Council's 1983 report on risk assessment  (1),
    Agency's Risk Assessment Guidelines (3)/     various program-
specific guidance (e*ge, the Risk Assessment Guidance for
Superfund)     obvious sources.  Twenty years of EPA experience
in developing,, defending/     enforcing risk assessment-based
regulation is another.  Together these various sources stress
importance of a clear explanation of Agency processes for
evaluating hazard, dose-response, exposuref     other      that
            scientific foundation for characterizing risk.
     This section focuses on two requirements for full
characterization of risk*  First/ the characterization
        qualitative and quantitative features of the assessment.
Second, it must identify any important uncertainties in
           as part of a discussion on confidence in the
assessment.
     This          on a full description of all elements'- of the
assessment'draws attention to the importance of     qualitative
as well as the quantitative dimensions of the assessment*  The
1983            carefully distinguished qualitative risk
           from quantitative assessments, preferring risk
statements that are not strictly numerical.
          The term                 is often given
          narrower and broader  meanings than we
          have         here.  For      observers,
          the term is synonymous with guantitatj.ve_

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                               emphasizes  reliance
          on numerical  results .   Our  broader  definition
          includes  quantification,  but  also includes
          qualitative expressions of  risk.  Quantitative
          estimates of  risk     not always feasible,  and
          they may  be eschewed by agencies for  policy
          reasons.   (Emphasis in original) (1)

          recently,  an  Ad    Study Group  (with representatives

•from .EPA, HHS,          private sector)  on Risk  Presentation

               expanded upon these principles by specifying

         "attributes" for risk characterization.

          1.        major components of  risk (hazard
               identification, dose-response,
               exposure assessment) are presented in
                        statements,  along with quantitative
               estimates of risk, to  give a combined
                    Integrated view of    evidence*

          2.   The  report clearly identifies
               assumptions , their rationale,  and
               extent of scientific consensus?
               uncertainties thus accepted!      the
               effect of reasonable alternative
               assumptions on conclusions     estimates.

          3.        report outlines specific ongoing or
               potential research projects that would
               probably clarify  significantly the extent
               of «nc«rtalaty In     risk estimation.
              .... (4)

      Particularly critical to foil characterization of risk Is a

               discussion of the uncertainty  in the overall

               in       of its components.  The  uncertainty

          Is •               several reasons .

                            different          carries
                 of  uncertainty      knowledge  of      differences
          Is  Important       uncertainties              for
          characterizing risk.

          Decisions must be      on expending resources to
                   additional information to
          uncertainties.

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          A^clear and explicit statement of the Implications and
          limitations of a risk assessment requires a clear and
          explicit statement of related uncertainties.

          Uncertainty analysis gives the decision-maker a better
          understanding of the implications and limitations of
          the assessments.

     A discussion of uncertainty requires comment on      issues

as     quality     quantity of available data, gaps in     data

     for specific chemicals, Incomplete understanding of general

biological phenomena,     scientific judgments or science policy

positions that      employed to bridge information gaps.

     In short, broad agreement exists on"the Importance of a full

picture of risk, particularly.including a statement of confidence

In                    that     uncertainties     within reason.

This section discusses information content and uncertainty

        of risk characterization^ while Section 3

        descriptors      In risk characterization.
                                10

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     1.  Th® risk assessment procass calls for charact®rizing
risk aa a combination of qualitativ* information, quantitative
information, and information regarding unc@rtainti@s.
     Risk assessment Is       on a series of questions that the
                    the          the Implications of the data 'for
      risk-       question calls for analysis     Interpretation
of     available studies, selection of          that
scientifically reliable          relevant to     problem at hand,
    scientific conclusions regjtrding the question presented*  As
          below, because the questions     analyses     complex,
a          characterization Includes several different kinds of
information, carefully selected for reliability     relevance.
     a«                         -- What do we            the
          capacity of an environmental agent for causing cancer
          (or other         effects) In laboratory animals     In

            identification Is a qualitative description       on
             as     kind     quality of data on        or
           animals,     availability of ancillary information
(e.g., structure-activity analysis,         toxicity,
kinetics)      other studies,     the weight~o£-the evidence
allvof            sources.  For example, to develop this
description^ th« Issues addressed Includei
     1.       nature, reliability,     consistency of the
          particular studies In            In laboratory animals;
     2*       available information on     mechanistic basis
          activity?
     3.   experimental animal responses     their relevance to
          human outcomes.
                       clear that the task of hazard
                                11

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identification is characterized by describing the full range .of

available information     the Implications of that information

for human health.

     b.                            ~~ What do we know about the
          biological mechanisms     dose-response relationships
          underlying any effects observed in the laboratory or
          epidemiology studies providing data for the

     The dose-response                     quantitative

relationships between* exposure (or dose)     effects in the

             to identify     define effects of concern.  This

Information is later used along with "real world" exposure

information (see below) to develop           of     likelihood of

        effects In populations potentially at risk* •

             for establishing dose-response relationships often

       on various assumptions used In lieu of a complete

             method chosen can strongly Influence the overall

assessment.  This relationship       that careful attention to

the choice of a high-to-low      extrapolation procedure Is very

Important*  As, a result, an assessor who Is characterizing a,

dose-response relationship considers several     Issues:

     1.   relationship between extrapolation models selected
          available Information on biological mechanisms;

     2.   how appropriate data      were selected from those
          show the range of possible potencies both In laboratory
          animals and humans;

     3.   basis for selecting interspeciea      scaling factors
          to  account for scaling       from experimental animals
          to humans; and

     4.   correspondence         the          route(s) of  .
         • exposure     the exposure route(s) utilized In. the
          hazard studies, as'well as the -Interrelationships of
          potential effects from different exposure routes.

                                12

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     EPA's Integrated Risk Information System (IRIS) Is a primary

source of this information.  IRIS Includes data summaries

representing Agency consensus on specific chemicals,       on a'

careful review of the scientific issues listed above.  For

         risk                   on      in IRIS and on other

sources, risk assessors should carefully review     information

presented, emphasizing confidence In the database and

uncertainties (see subsection d below).  The IRIS statement of

           should be included as part of the risk

characterization for hazard     dose-response Information.


     c.                       •- What do we know about the       ,
          patterns,     magnitudes, of human exposure
          of         likely to be

                                      a wide range of

           pertaining to     "real world" environmental

of                be         to the             study.  The

           for     exposure assessment range froa monitoring

        of chemical concentration* In environmental media, food,

          materials to information, on activity patterns vof

different population subgroups.  An assessor who characterizes

         should         several Issues.

      1.       basis for     values     Input parameters
               exposure scenario*  If       on data, Information
          on the quality, purpose,     representativeness of
          database la needed.  If       on assumptions,
                     general logic used to develop the assumption
           (e.g., monitoring »> modeling, analogy, professional
           judgment) should be described.
                                13

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     2.       major factor or factors (e.g., concentration, body
          uptake, duration/frequency of exposure}  thought to
          account for the greatest uncertainty In the exposure
          estimate, due either to sensitivity or lack of data.

     3.   The link of the exposure Information to the risk
          descriptors discussed in Section 3 of this Appendix.
          This Issue includes the conservatism or non-
          conservatism of the scenarios, as Indicated by the
          choice of descriptors.

     In summary, confidence in the Information used to

characterize risk Is variable, with the result that risk

characterization requires a statement regarding the assessor's

confidence in each        of the assessment.

     d.                         — What do other assessors,
          decision-makers,     the public need to know about
          primary conclusions     assumptions,           .the
          balance between confidence and uncertainty In the
          assessment?

     In     risk characterization, conclusions about hazard

              are integrated with       from'the

assessment.  In addition^ confidence about these conclusions,

Including Information       the uncertainties associated with

final  risk summary, is highlighted.  As summarized below,

characterization Integrates all of     preceding Information to

communicate the overall meaning of,     confidence In,

hazard, exposure,     risk conclusions.

     Generally, risk             carry two categories of  .

uncertainty,     each merits consIderation.  Measurement

•uncertainty refers to the usual variance that accompanies

scientific               (such as     range around an

estimate)      reflects the accumulated variances around the

Individual          values used to develop     estimate.  A

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different kind of  uncertainty        from data gaps -- that  is,
Information needed to complete the data base' for the assessment.
Often, the      gap is broad, such as the absence of information
on     effects of  exposure  to a chemical on  humans or on the
biological mechanism of  action of an      .
     The        to which confidence     uncertainty in      of
            is                   largely on  the       of the
                    resources available.  For example, the Agency
     not        an           to evaluate     assess every
conceivable          scenario for every possible pollutant, to
        all susceptible  populations potentially at risk, or to
             every possible environmental scenario to determine
              effect relationships         exposure to pollutants
            health effects.  Rather, the uncertainty analysis
       reflect      type  and complexity of     risk
         level of        for analysis     discussion of
uncertainty corresponding to     level of effort for
                          of                 of uncertainty
          below.
     Often risk assessors     managers simplify discussion of
risk       by  speaking  only of the  numerical            of an
             That  is, they  refer to  ch« weight-of-evidence, unit
risk,     risk-specific      or      ql* for  cancer risk/
'RfD/RfC     health effects  other than cancer, to the exclusion of
       Information  bearing on     risk case*  However,
           carries uncertainties, a  simplified numerical

                                15

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presentation of risk Is always Incomplete and often misleading.
For this reason, the      (1) and EPA risk assessment guidelines
(2} call 'for "characterizing" risk to include qualitative
information, a related numerical risk estimate and a discussion
of uncertainties, limitations/     assumptions.
     Qualitative Information on methodology, alternative
interpretations,     working assumptions Is an important
component of risk characterization.  For example, specifying
       studies rather than human studies were used in an
           tells others that the risk estimate ia       on
assumptions about human          to a particular chemical rather
           data.  Information that human          estimates
      on the subjects'          In the vicinity of a chemical
accident rather than tissue measurements defines known
unknown aspects of the exposure component of the study*
     Qualitative descriptions of this kind provide crucial
Information that augments understanding of numerical risk
estimates.  Uncertainties such as           expected In
scientific  studies     In any risk                  on 'tfiese
studies.  Such uncertainties do not        the validity of
assessment*  Rather, they are highlighted along with other
          risk assessment conclusions to Inform others fully on
     results of the assessment.
                                16

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     2-.  **®li-balanc€d risk characterization pr«s®nts information
for oth«r risk assessor®, EPA dscision-makera,, and th® public
regarding th« strengths     limitations of th« assessment.
         risk assessment process calls for identifying
highlighting significant risk conclusions and related
              partly to        full communication       risk
              partly to        that decision-Bakers     fully
informed.  Issues     identified by acknowledging noteworthy
qualitative     quantitative factors that      a difference in
    overall assessment of hazard and risk, and hence in the
ultimate regulatory decision.
             word is "noteworthy":  information that
significantly influences     analysis is retained •— that is,
      —- in all future presentations of the risk
in             decision.  Uncertainties
strongly influence confidence in     risk
        attention.
     As           earlier, two major         of uncertainty
variability in     factors upon which
          of fundamental      gaps.  This distinction is "relevant
for              of     risk characterization.  For example,
central              high     individual exposure estimates
         to                         in exposure, lifestyles,
                   lead to a distribution of risk across a
population.  Key considerations underlying       risk
       be fully described.  In contrast, scientific
         to        knowledge gaps  such as         of scaling or

                                17

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extrapolation factors     the use of a particular upper
confidence limit around a dose-response estimate.  Such
assumptions need to be discussed separately, along with the
implications of using alternative assumptions.
     For users of                    others who rely on
assessment, numerical estimates should never be separated from
    descriptive information that is integral to risk
characterization.  All documents     presentations should include
both? in short reports,, this information is abbreviated but never
omitted.
     For decision-makers, a complete characterization (key
descriptive elements along with numerical estimates) should be
retained in all discussions and papers relating to an assessment
     in decision-making.  Fully visible information assures that
important  features of     assessment     immediately available at
     level of decision-aaking for evaluating whether risks
acceptable or unreasonable.  In short, differences in
    uncertainties, coupled with non-scientific considerations
called for in various environmental statutes, can clear 1-y      to
different  risk management decisions in ca-ses with ostensibly
identical  quantitative risks; i.e., the "number™ alone      not
determine  the decision.
     Consideration of alternative approaches involves
selected plausible options  for addressing a given uncertainty.
The     words are  "selected"      "plausible;"  listing all
options, regardless  of their merits would be superfluous.

                                18

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Generators of the assessment should outline the strengths and

weaknesses of each alternative approach     as appropriate,

          of central tendency     variability (e.g., mean,

percentll.es,, range, variance.)

     Describing     option chosen Involves several statements,

          1.   A rationale for     choice.

          2.   Effects of option selected on the assessment.

          3.   Comparison with       plausible options.

          4.   Potential         of              (on-going,
               potential near-term and/or long-term studies),

          of     assessmentr giving attention to uncertainties In

all               discussions'involving the assessment*

               statement of confidence In all presentations  is

            For decision-maker s i> understanding     effect of

              on     overall                explaining

          of     uncertainties on     regulatory

.decision.
                                19

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      SECTION  3,                       AMD  RISK  DESCRIPTORS
     The results of a risk assessment are usually communicated to
the risk manager in the risk characterization portion of the
assessment.  This communication is often accomplished through
risk_descri£tors which convey information and answer questions
about risk, each descriptor providing different information
insights.  Exposure assessment plays a key role in developing
      risk descriptors, since each descriptor is       in      on
the          distribution within the population of interest.  The
                Council (RAC)          discussing         of risk
descriptors from      to      over     past two years.
         recent RAC efforts      laid     foundation for
discussion to  follow.  Pirstr as a result of a discussion
on the comparability of risk assessments across the Agency
programs? the  RAC discussed how the program presentations of risk
    to ambiguity when risk assessments were compared
programs.  Because different assessments presented different
descriptors of risk without always making clear what was
described, the RAC discussed the advisability of using-
descriptors for population risk, individual risk,
identification of sensitive or highly exposed population
segments*          also discussed          for consistency
             the advisability of requiring risk assessments to
provide  roughly comparable information to risk' managers     the
public  through the use of a consistent     of risk descriptors.
                                20

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     The following guidance outlines the different descriptors In
a convenient order that should not be construed as a hierarchy of
importance.  These descriptors should be used to. describe risk In
a variety of ways for a given assessment, consistent with
assessment's purpose, the data available^ and the Information the
risk         needs*  Use of a range of descriptors Instead of a
single descriptor enables Agency programs to present a picture of
risk      corresponds to     range of different exposure
conditions encountered for most environmental chemicals.  This
analysis, In turn* allows risk managers to Identify populations
at greater     lesser risk     to shape regulatory solutions
accordingly.
     EPA risk assessments will be expected to address or provide
descriptions of  (1) Individual risk to Include the central
             high     portions of the risk distribution,
(2)           subgroups of     population such as highly
or highly susceptible groups or Individuals, if known,
(3) population risk*  Assessors may also use additional
descriptors of risk as needed when these add to the clarity of
    presentation*  With     exception of
particular descriptors clearly do not apply,      form of
            of descriptors should be routinely developed
•presented for EPA risk assessments.  Furthermore, presenters of
risk assessment  Information should be prepared to routinely
answer questions by risk managers concerning these descriptors.
                                21

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     Tt is essential that presenters not only communicate the
results of the assessment by addressing each of the descriptors
where appropriate, but they also communicate their confidence
that       results portray a reasonable picture of the actual or
projected exposures.  This task will usually be accomplished by
highlighting the key assumptions     parameters that have
greatest        on the results, the basis or rationale for
choosing       assumptions/parameters/     the consequences of
choosing other assumptions.
     In order for     risk assessor to successfully develop
present     various risk descriptors, the exposure
     provide          and      information in a form that can be
         with exposure-response or dose-response relationships to
         risk*  Although there will be differences among
individuals within a population as to absorption, intake rates,
susceptibility/ and other variables such that a high
     not necessarily result in a high      or risk, a moderate or
highly positive correlation among exposure/ dose/ and risk is
        in the following discussion.  Since the generation of all
descriptors is not appropriate in all risk assessments
     of descriptor translates  fairly directly into the      of
analysis that the exposure assessor must perform/ the exposure
assessor needs to be aware of  the ultimate goals of
assessment*  The  following.sections discuss what type of
information  is necessary.
                                22

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     r. Information about jLndiy_iduai ®xpo®ur€      risk  is
important to communicating  thm  results of a risk
     Individual risk descriptors     intended to

questions dealing with risks borne by individuals within a

population.  These questions can      the      of:

                  the people at the highest risk?

          What risk levels are they subjected to?

          What          doing, where do they live, etc., that
                be putting      at this higher risk?

          What Is     average risk for individuals In the

          population of interest?

     Tr.T "h->- ar.d" cf the r.sk --f •' strf.b-rtitr. is, conceptually,

          90th percent He of     actual (either          or

           distribution.  This conceptual       Is           to

                 the limits of this descriptor, but should be

     by              as a              for characterizing "high

    risk".  Bounding               worst      scenarios1 should

    be                 risk

              high     risk descriptor is a plausible
                   of     individual risk
                  at     upp^z1     of     risk
          distribution.  The Intent of this descriptor
          Is to convey an          of risk In
                      of     distribution, but to
          avoid estimates which     beyond the
     1 High     estimates focus on estimates of the          or
     in     actual populations*   "Bounding estimates," on
      hand, purposely overestimate the exposure or dose In an
actual population.for the purpose of developing a statement that
    risk Is "not greater than...."  A "worst cas« scenario"
       to a combination of  events    conditions such that,
together,          the highest conceivable risk.  Although It  Is
         that  such an exposure, doser or sensitivity combination
            In a given population of Interest, the probability of
an Individual  receiving this  combination of events     conditions
Is usually small,     often so small that such a combination will
    occur In a particular,  actual population.

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          true distribution.  Conceptually, high
          end risk means risks'       about the
          90th percentile of the population
          distribution, but not higher than the
          individual in the population who
          the highest risk.
     This descriptor is intended to estimate     risks that are
         to       in small     definable "high end"          of
    subject population.  The individuals with these risks may be
        of a special population         or individuals in the
general population who     highly         because of the inherent
stochastic nature of     factors which give rise to exposure.
      no particular difference in sensitivity can be identified
within     population,     high     risk will be related to
high     exposure or dose.
     In those few       where the complete data on the population
distributions of exposures               available, high
         or                    be represented by reporting
          or       at selected percentiles of the distributions,
     as the 90th, 95th, or 98th percentile.  High
or doses, as appropriate, can then be used to calculate high
risk estimates.
     In     majority of cas-ea where the complete distributions
        available, several methods help estimate a high
         or dose.  If sufficient information about
.variability in  lifestyles and       factors     available to
simulate the distribution through     use of appropriate
modeling, e.g.,  Monte Carlo  simulation, the estimate from the
simulated distribution may be used*  As in the -method above,
risk manager should be told  where  in the high     range the

                                24

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         Is being       by  stating  the percentile or  the  number  of
               this  estimate.   The  assessor and risk  manager
'should be aware, however,  that unless a great deal is  known  about
                     at .the high     of     distribution,
          will Involve  considerable uncertainty which
                  will       to describe.
      If only  limited information on     distribution of
         or              la available, the assessor  should
         estimating     high    by Identifying the
sensitive                using        or near-maximum values  for
    or a      of      variables/ leaving others at their
values2.  In  doing  this, the          assessor       to  avoid
              of           values that     Inconsistent,  e.g.,,  low
      weight      in combination with high Intake rates,
      in          ultimate  objective of       within  the
distribution  of actual                        doses,
       it.
    -  If         no           available on
various parameters, It  will be difficult to estimate'           or
      In      high     with     confidence,     to
         risk estimate*  One       that               in
      is to  start with  a                      "back off"
.limits       until     combination  of           values  is, In
      2             all  variables will  In virtually all cases
 result  In an estimate  that Is above     actual values       in
 population.   When the  principal             of           equation
 (e.g.,  concentration,  Intake rate, duration)     broken out into
 subcomponentsf  It may  be necessary to            values for
 than two of  these subcomponent parameters,  depending on a
 sensitivity  analysis.

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judgment of the assessor, clearly within the distribution of
         exposure, and still lies within the upper 10% of persons
          Obviously, this method results in a large uncertainty
    requires explanation.
          The risk descriptor addressing central •
          tendency may be either the arithmetic
               risk (Average Estimate) or
                 risk (Median Estimate), either
          of which^should be clearly la- "ad.
          Where both the arithmetic mean -,™*d
          the median are available but tn~y
          differ substantially, it is helpful
          to present both.
     The Average Estimate,      to approximate     arithmetic
mean,     be derived by using         values for all
factors.  It      not necessarily represent a particular
individual on the distribution.  The Average Estimate is not very
meaningful when exposure across a population varies by several
       of magnitude or when the population          truncated,
e.g., at      prescribed distance from a point source.
             of the skewness of typical exposure profiles,
arithmetic      is not necessarily a good indicator of
          (median,  50th percentile) of a distribution* ' A Median
Estimate, e.g., geometric mean, is usually a valuable descriptor
for this  type of distribution, since half the population will be
      -and half below this value*
                                26

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     2. Information about population ®xpo®ur® l®ad® to anoth@r
important way to d®»crib€ risk.

     Population risk refers to an assessment of the extent of

             population as a whole.  In theory, It     be

calculated by summing the Individual risks for all Individuals

within             population.  This taskr of coursef requires a

      deal      Information than Is normally, If ever* available.



          questions           by descriptors of population risk

Includet

          How many       of a particular health effect might be
          probabilistically           In this population for a
                        period?

          For noncarclnogens, what portion of the population
          within a                 of                level* e.g.,
                     of         (a doae),     RfC (a
          concentration), or other health         level?

              carcinogensr     many             above a certain
          risk level such as 1Q~6 or a        of risk levels
          as 10""5,  10"4r

                               requires                of

                   distribution in     population.  In

particular,                           third

             risk distribution,        questions          to

                      of population risk.

              first descriptor Is     probabilistic
                 o£ health effect cases estimated
          in     population of Interest      a
          specified      period.

     This descriptor can be obtained either by  (a)

Individual risks over all     Individuals In     population

     Information la available, or  (b) through the     of a risk

model  such as carcinogenic models or procedures which        a


                                27

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linear non-threshold response to exposure.  If risk varies

linearly with exposure, knowing the      risk and the population

size can lead to an estimate of•the extent of harm for

population as a whole, excluding sensitive subgroups for which a

different dose-response curve needs to-be used.

     Obviously, the      information     has,          certain

    estimate of this risk descriptor, but inherent uncertainties

in risk assessment methodology place limitations on     accuracy

of     estimate.  With the current state of the science, explicit

      should be taken to assure that this descriptor is not

confused with an actuarial prediction of cases in the population

(which is a statistical prediction       on a great deal of

empirical data).

     Although estimating population risk by calculating a

individual risk     multiplying by     population size is

          appropriate for carcinogen             using linear,

non-threshold models3, this is not appropriate for non-

carcinogenic effects or for other types of cancer models.  For

non-linear cancer models, -an estimate of population risk      be

calculated by         individual risks.  For non-cancer effects,

we generally have not developed the risk assessment techniques to

    point of knowing how to add risk probabilities, so a second

.descriptor, below,  is more appropriate.

          Another descriptor of population risk
          is an estimate of the percentage of
          the population, or the number of
          persons,  above a specified level of
      3 Certain  important  cautions apply.  These cautions
 explicitly spelled out in the  Agency's  Guidelines for Exposure
 Assessment,  tentatively scheduled to be published in late  1991.

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          risk or within a specified range of
               benchmark level, e.g., exceedance
          of the RfD or the RfC, LOAEL, or other
          specific level of interest.

This descriptor must be obtained through measuring or simulating

    population distribution.
                                29

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     3. Information about the distribution of ®xposur@ and risk
for dlf£«c«nt £ub3rou£§ of tfa® population arm important
component* of a risk assessment.

     A risk manager might also ask questions about the

distribution of the risk burden among various segments of

subject population such as the followingi

          How do              risk        various subgroups.?

          What Is the population risk of a particular subgroup?

Questions       the distribution of exposure     risk       such

population segments require additional risk descriptors.


          Highly                   can be
          identified,     where possible, characterized
              the magnitude of risk quantified.
          This descriptor Is useful when there
          Is  (or Is          to be) a subgroup
          experiencing significantly different
                    or       from that of the
          larger population.

     These subpopulations     be identified by age, sex, life-

style, economic factors, or other demographic variables.

example, toddlers who play in contaminated soil and certain high

fish consumers represent subpopulations that may have

          to certain agents.

          Highly susceptible subgroups can also
          be  Identified,     If possible,
          characterized     the magnitude of
          risk quantified. This descriptor Is
          .useful when the sensitivity or
          susceptibility to the effect for
          specific subgroups is  (or Is
                   to be) significantly
          different from that of     larger
          population.  In order to calculate
          risk for these subgroups, It will
                    be necessary to use a
          different dose-response  relationship.
                                30

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For example, upon          to a chemical,          women,  elderly
people, children, and people with certain illnesses may each be
     sensitive than the population as a whole.
     Generally, selection of     population          is a matter
of        a priori interest in     subgroup, in which
risk              risk manager can jointly agree on which
          to highlight, or a        of discovery of a sensitive
or highly                  during the assessment process.   In
       case,      identified,              can be         as a
population in itself,     characterized          way as
       population using the descriptors for population
individual risk.
                                31

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     4. Situation-specific  information  adds  p«rsp«ctiv®  on
posslbl®  futur®  «v®nts  or regulatory  options.

     These  postulated questions are normally designed to answer

"what  If" questions,  which      either directed at low probability

but possibly high consequence events  or are  intended to

candidate risk management options.  Such questions might

.following form;

               What if  a pesticide  applicator  applies
               this pesticide without using  protective
               equipment?

               What if  this site         residential
               in the future?

               What risk level will occur if we set
               the standard at 100  ppb?

     The  assumptions      in answering  these postulated  questions

            be confused  with     assumptions       in developing a

          estimate of exposure or with the adjustments in

          values      in performing a sensitivity analysis.   The

         to  thes'e postulated questions do not give information

about  how likely the combination of values might be in the actual

population  or about how many (if any) persons  might be -subjected

to     calculated exposure or risk in     real world.

          A calculation of risk      on specific
           hypothetical or actual combinations
           of factors postulated within  the
           exposure assessment can also  be
           useful as a risk descriptor.   It
           is often valuable to ask     answer
           specific questions of the "what if"
           nature to     perspective to  the
           risk assessment*

      The'only information the answers to these questions convey

 is that if  conditions A, B,     C     assumed, then     resulting

 exposure or risk will be X, Y, or Z,  respectively.  The  values

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for X/ Y, and Z are usually fairly straightforward to calculate
and     be expressed as point estimates or ranges.
Each            may have none, one, or several of these types of
descriptors.  The answers d© not directly give information about
how likely that combination of.values might be in the actual
population, so there are some limits to the applicability of
these descriptors.

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                       Rjr5>pc«_5


National Research Council.  Risk Assessment in the Federal
Governmenti  Managing the Process.  1983

U.S. EPA.  Risk Assessment     Managementi  Framework  for
Decision Making,  1984,

UaS* EPA.  Risk Assessment Guidelines.  51 Federal Register
33992-34054.            24, 1986.

Presentation of Risk Assessment of Carcinogens; Ad      Stcdy
Group on Risk Assessment Presentation.  American Industrie.!
Health Council.  1989.
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