Primary prevention and precaution in hazard identification in the NIEHS/NTP: body in the morgue approach

In the spirit of stimulating reevaluation of the methods of public health science, this article explores the methods of cancer hazard identification at the National Toxicology Program (NTP) from the perspective of primary prevention and precaution. The NTP is a cooperative effort of three federal agencies: The National Institute of Environmental Health Sciences (NIEHS, the lead government institute); the National Institute for Occupational Health (NIOSH), in the Centers for Disease Control and Prevention; and the National Center for Toxicology Research (NCTR), in the Food and Drug Administration. NTP coordinates toxicological research and testing programs within the Department of Health and Human Services (DHHS), and through its annual Report on Carcinogens (RoC), identifies and characterizes cancer hazards-the first step in quantitative risk assessment-for the federal government. The foundation of NIEHS policies, for environmental health research, is quantitative risk assessment (QRA). The author examines the opportunities for primary prevention and precaution, and the extent to which the policies of NIEHS in general, and the NTP in particular, do and do not realize that potential. Special attention is paid to the issue of cancer hazard identification. Critical comments on the process of classifying carcinogens in the Ninth and Tenth Reports on Carcinogens are presented, based on the minutes of the Board of Scientific Counselors Subcommittee meetings.