OMB Strengthens Agency Risk Assessment Process
On September 19, 2007, the US Office of Management and Budget, and the US Office of Science and Technology Policy, published a Memorandum for Heads of Executive Departments and Agencies entitled Updated Principles for Risk Analysis. This Memorandum strengthens federal agencies' risk assessments in several ways, but in particular by expressly incorporating the Data Quality Act requirements into the agency risk assessment process, as required by law.
For example, the memorandum points out that "the Information Quality Guidelines state that agency disseminations should be objective; these guidelines, as well as individual agency information quality guidelines, provide further discussion of objectivity and its application in agency disseminations."
The Memorandum further states, "Agencies should employ the best reasonably obtainable scientific information to assess risks to health, safety, and the environment." The Memorandum uses the 1996 amendments to the Safe Drinking Water Act as precedent for this standard. The Memorandum then explains, "Agencies have adopted or adapted this SDWA standard in their Information Quality Guidelines with regard to the analysis of risks to human health, safety, and the environment."
In addition the Memoranda explains, "When something more than superficial analysis can be conducted, quantitative uncertainty analysis, sensitivity analysis, and a discussion of model uncertainty can greatly inform risk management decisions."
The Memorandum will be useless if agencies don't follow it. The Memorandum states that "OMB and OSTP will work with Federal agencies to ensure consistency with the principles in the memorandum. Agencies should review their current risk analysis practices and guidelines and incorporate these principles as they develop, update, and issue risk analyses and guidelines."
This follow-through by OMB and OSTP is essential to implement the Memorandum and improve the federal agency risk assessment process.
Click here to read OMB Risk Assessment Memorandum
®: CRE Regulatory Action of the Week