Thursday, April 22, 2010

Risk Analysis

From time to time the Gummit issues documents of extreme importance that get lost in the cacaphony of events. Separating the wheat from the chaff is perhaps one hope of this blogger.
The NAS Disaster Roundtable has a hugely important session coming up in early June on Risk Assessment and Analysis. These are usually quite interesting sessions and a divergant group provides interesting points of view. Brief summaries of each session are also available on the NAS Disaster Rountable site.
At any rate during the later part of the Administration of George W. Bush a memo issued forth that to my knowledge still stands as mandatory guidance and has not been repealed or superseded by the Obama Administration. So I have briefly extract just the front page for this blog post but recommend all attending the forthcoming Roundtable or those involved in Risk Analysis and Risk Assessment become familiar with it. The extract follows:

September 19, 2007
M-07-24
MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES
FROM: Susan E. Dudley
Administrator, Office of Information and Regulatory Affairs,
Office of Management and Budget
Sharon L. Hays
Associate Director and Deputy Director for Science,
Office of Science and Technology Policy
SUBJECT: Updated Principles for Risk Analysis
Federal agencies take a variety of actions to improve public health, safety, and the environment. Agency activities designed to reduce risks are influenced by numerous factors, including Congressional priorities, information on the degree of risk faced by different populations, entities, or individuals, resources available, and the ease of implementing chosen priorities. Development of these actions often begins with an assessment of the risks posed under certain conditions, as well as assessments of the potential changes in risk achievable due to different policy options.
In 1995, an interagency working group, co-chaired by the Office of Management and Budget (OMB) and the Office of Science and Technology Policy (OSTP), developed a set of principles to guide policymakers in assessing, managing, and communicating policies to address environmental, health, and safety risks (the 1995 Principles).1 The 1995 Principles, shared with regulatory agencies in a memorandum from Sally Katzen, then Administrator of OMB’s Office of Information and Regulatory Affairs (OIRA), remain valid today.
This Memorandum reinforces the 1995 Principles with reference to more recent guidance from the scientific community, the Congress, and the Executive Branch. This Memorandum also benefits from feedback received on OMB’s Proposed Risk Assessment Bulletin issued in 2006 (Proposed Risk Assessment Bulletin).2
1 U.S. Office of Mgmt. and Budget (OMB), Memorandum for the Regulatory Working Group, Principles for Risk Analysis (1995), available at http://www.whitehouse.gov/omb/inforeg/regpol/jan1995_risk_analysis_principles.pdf.
2 OMB, Proposed Risk Assessment Bulletin, (2006) [hereinafter Proposed Risk Assessment Bulletin], available at http://www.whitehouse.gov/omb/inforeg/proposed_risk_assessment_bulletin_010906.pdf