273 



The Agency has considered this issue on a number of occasions over the past ten 

 years. The 1983 National Academy of Science (NAS) report addressed this question 

 and found that, although a conceptual separation of risk assessment and risk man- 

 agement was necessary, the process by its nature needed to be interactive and did 

 not support an independent group of risk assessors. The wisdom of that finding has 

 become more evident as the need to tailor risk assessment fmdings to statutory lan- 

 guage was recognized; as the need to have Agency experts defend risk assessment 

 findings in the courts has grown; and as Agency priorities determined the need for 

 sjjecific risk assessments. Each of these would be difficult if not impossible if an in- 

 dependent agency were producing "one size fits all" risk assessments. 



This is not to say that there are no benefits from attempting to have uniform ap- 

 proaches to Government risk assessments. Various groups have been established to 

 work toward that end in the last ten years. The most recent through the Federal 

 Coordinating Council for Science, Engineering, and Technology (FCCSET), has made 

 significant progress in this area. 



Question 5: 



Commentators have suggested that programs currently managed by other depart- 

 ments should be consolidated within the EPA. 



For example the Carnegie Commission and the Institute of International Econom- 

 ics recommend, at a minimum, that programs from the Commerce Department (e.g. 

 NOAA) and the Interior Department (e.g. USGS) should become part of the EPA. 



Would you please comment on these recommendations. 



I noted in my testimony one of the primary reasons for elevating EPA to cabinet 

 status is to improve environmental policy integration and coordination among Fed- 

 eral gigencies. However, I would not support a restructuring of environmental pro- 

 grams from other Departments as part of the EPA Cabinet legislation. Major im- 

 provements in integration and coordination across Departments can be made 

 through better communication, information sharing, and joint problem solving. For 

 instance, I now meet personally on a monthly basis with the Secretary of the De- 

 partment of Interior, the Department of Agriculture, and the Department of 

 Energy, to foster this type of collaboration across the Executive Branch. 



