•...• >4 mj 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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* ------- 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 ------- 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. ------- 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 ------- 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. ------- 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_ ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 14 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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. 34 ------- |