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by George E. Parris Phd (Author)
This essay briefly summarizes the scientific errors in the linear, no-threshold (LNT) dose-response model for carcinogens, and explores the issue of the target for acceptable risk used to set regulatory standards by the US Environmental Protection Agency. While the LNT theory has been a regular topic of scientific criticism in scientific journals and elsewhere, the fallacies in the policy of setting targets for acceptable risk are less appreciated. The risk target used by the US Environmental Protection Agency (i.e., one-in-one-million lifetime risk of death) has its root in a brief, casual and fallacious conversation between to government bureaucrats. It is argued that the national target for acceptable risk is an issue that should be addressed by elected officials in Congress after through debate rather than promulgated by rule by a government agency. Divorced from science (contrary to Federal law), enforceable regulations from the EPA become the playground of conflicting political, emotional and economic interests. The combination of (i) the over estimation of risk from low-dose chemical exposure via the LNT and (ii) the excessively conservative targets for chemical risk management have created regulatory schemes that are economically destructive, suppress innovation and are (ironically) excessively risky.
