Does EPA Underestimate Cancer Risks by Ignoring Susceptibility Differences?

A 2009 report of the National Research Council (NRC) recommended that the U.S. Environmental Protection Agency (EPA) increase its estimates of increased cancer risk from exposure to environmental agents by ∼7‐fold, due to an approximate ∼25‐fold typical ratio between the median and upper 95th percentile persons’ cancer sensitivity assuming approximately lognormally distributed sensitivities. EPA inaction on this issue has raised concerns that cancer risks to environmentally exposed populations remain systematically underestimated. This concern is unwarranted, however, because EPA point estimates of cancer risk have always pertained to the average, not the median, person in each modeled exposure group. Nevertheless, EPA has yet to explain clearly how its risk characterization and risk management policies concerning individual risks from environmental chemical carcinogens do appropriately address broad variability in human cancer susceptibility that has been a focus of two major NRC reports to EPA concerning its risk assessment methods.