EPA Review of draft Baseline Ecological Risk and Human Health Risk Assessments

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In its initial review of the draft Baseline Ecological Risk and Human Health Risk Assessments provided by the Lower Willamette Group, the EPA has identified several deficiencies in the determination and reporting of risks.
"The risk assessments tend to minimize the risks to human health and the environment. For human health, the BHHRA improperly overstates the conservative nature of the human health risk assessment, overstates the uncertainties in the HHRA, and pre-maturely identifies “risk drivers” as a subset of the COCs.   The BERA eliminates lines of evidence, such as comparison of bulk sediment chemical concentrations to published sediment quality guidelines that were directed by EPA to be used in the BERA.  The BERA also prematurely makes risk management decisions by eliminating COCs and lines of evidence (LOEs) in the risk characterization sections of the BERA."
Read report by Scott Learn in the Oregonian: Milestone report on Portland Harbor pollution lowballs risk EPA ...
Relevant documents are posted at:
EPA Risk Assessment comments to LWG (PDF) (15pp, 168K) - December 23, 2009

Center for Progressive Reform

Catherine O'Neill, Associate Professor of Law, Seattle University School of Law, posted a blog at the Center for Progressive Reform "EPA Chides Polluters for Downplaying Risk From Portland Harbor Superfund Site; Still, Must Honor Fishing Tribes' Rights".