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Regulation of Radiological and Chemical Carcinogens: Current Steps Toward Risk Harmonization

December 1995

Citation: 25 ELR 10657

Issue: 12

Author: David P. Overy and Allan C.B. Richardson

Editors' Summary: Until recently, the regulation of chemical carcinogens and the regulation of radiological carcinogens developed independently. Different governmental agencies operating under different statutory directives were responsible for addressing the dangers from these carcinogens. As a result, different policies and practices were developed. This Article explores these differences and the record on resolving them. It first examines the history of federal regulation of chemical and radiological carcinogens and summarizes EPA's approach to risk assessments for them. It then analyzes the traditional risk management approach for radiation, as exemplified by the recommendations of the International Commission on Radiological Protection (ICRP), and compares this approach to the approaches EPA has taken. Finally, the Article compares the results obtained under these approaches. It concludes that EPA's radiation standards, which in many cases were derived under policies applicable to chemical carcinogens, are, for the most part, consistent with the ICRP's recommendations.

David P. Overy is an attorney advisor in the Federal Facilities Enforcement Office of the U.S. Environmental Protection Agency (EPA). At the time this Article was being prepared, he was attorney advisor and special assistant to the Director, Office of Radiation and Indoor Air, EPA. Allan C.B. Richardson is Associate Director for Radiation Guidance, Radiation Protection Division, Office of Radiation and Indoor Air, EPA.

This Article represents the views of the authors in their individual capacities and does not necessarily reflect the position of EPA or the U.S. government. The authors thank those who reviewed and commented on this Article, including Margo Oge, Gordon Burley, Bob McGaughy, George Wyeth, Chuck French, John Davidson, Stuart Walker, Robert Fegley, Tim Gill, and Judy Tracy.

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