Suggested Additional Wording For HR 2727

The following is a letter to the Hon. Sherwood Boehlert suggesting additional wording in HR 2727 reinforcing the use of unbiased probablistic risk assessment.

November 6, 1997

The Hon. Sherwood Boehlert
US House of Representatives
Washing ton, DC 20215
Via E-mail

Dear Mr. Boehlert:

I have read HR 2727 and believe it to be a great improvement to the present law and practices especially in the areas of risk assessment, remediation selection and long term stewardship. However, based on several years experience with EPAs interpretation of the law, their guidelines and their propensity to use inappropriately biased data, I would suggest adding the following item as item 2) to the list in:

`SEC. 127. RISK ASSESSMENT PRINCIPLES, GUIDELINES, AND REVIEWS. `(a) GENERAL PRINCIPLES- Risk assessments and characterizations

NEW ITEM:

'(2) include a probabilistic determination of the risk, its protective percentiles and its uncertainty based upon unbiased distribution functions or other unbiased estimates of site specific parameters;

I believe that this wording will reinforce HR 2727s intent to use the best scientific methods and avoid the current biased risk assessments and the resulting costly remediations of doubtful value. The methods suggested by these words are well within the state-of-the-art and should not pose a serious burden on knowledgeable risk assessors.

Respectfully yours,

__________________
/s/ Alfred A. Brooks