Quantitative risk assessment: qualms and questions

Within the past ten years, quantitative risk assessment has come to play a central role in the federal regulation of carcinogens. Federal agencies use quantitative risk both to set priorities and to establish exposure levels. The use of quantitative risk assessment is mandated by Executive Orders requiring performance of cost-benefit analysis, although performance of assessments has often been ascribed to the Supreme Court decision in the 1980 "benzene" case. Quantitative risk assessment is a deeply flawed methodology with results that give a false sense of certainty and objectivity. Also, the nature of quantitative risk assessment methodologies currently in use makes it difficult for members of the public to scrutinize and assess regulatory actions. Quantitative risk assessment should not be used for regulation of carcinogens, especially not for establishing exposure levels. Instead, alternative methodologies should be utilized, which are appropriately reflective of uncertainty and which are more readily accessible to public scrutiny and participation.