Today the Office of Management and Budget issued a memorandum to agency heads directing them to adhere to certain principles of risk analysis. The memorandum is OMB’s initial response to the report of a National Research Council panel that OMB asked to review a 2006 proposed bulletin on risk assessment. That report called the proposed text “fundamentally flawed” and gave seven recommendations, one of which was that it be withdrawn.
A fair reading of the new memorandum is that OMB followed this specific recommendation.
The principles contained in the memorandum are identical to those published by OMB in 1995. Shortly after Neutral Source was established, we posted this document in our library because it was not otherwise publicly accessible on OMB’s website, or anywhere else on the web. (A Google search reveals no other hits besides Neutral Source; it was recently posted by OMB.)
Because the document has not been available, it is reasonable to infer that its principles are generally unknown, and similarly likely that they were never implemented. This document was a precursor of OMB’s 2006 proposal; it is cited in footnote 6 (PDF page 3) to support the claim that the proposal “builds upon the historic interest that both OMB and OSTP have expressed in advancing the state of the art of risk assessment.” However, the National Academy panel does not appear to have examined the document; it is not cited anywhere in the panel’s report despite its obvious relevance. Sally Katzen, the Administrator of OMB’s Office of Information and Regulatory Affairs in 1995 and the author of OMB’s 1995 risk analysis principles, served on the Academy panel.