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Human and Experimental Toxicology

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Professor Cross provides a preliminary examination of how the regulatory structure of the United States might deal with the reality of hormetic effects. My comments focus on only one aspect of that issue: the scientific uncertainty in fact finding about hormetic effects, and the cost of reducing such uncertainty to an acceptable level. Under federal law in the United States, administrative actions are generally unlawful if a court finds them to be 'arbitrary or capricious.In practice, this means that in order for a rulemaking, licensing decision, or administrative order to be lawful, there must be a rational basis for the action. The administrative action must be based on a consideration of all the relevant factors, and there must be an understandable, coherent rationale for the decision that is justified under the agency's statutory mandate.My main points in these comments are that factfinding about hormetic effects must be warranted by the available evidence, that the cost of reducing scientific uncertainty about hormetic effects in particular cases is substantial and sometimes prohibitive, and that the science policies needed to fill the residual gaps in scientific information must continue to be justified within the confines of the relevant statutory mandates.


Originally printed in 8 Belle Newsletter 37 (2000)



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