An Example of Decision-Making on Environmental Carcinogens: The Delaney Clause

William P. Darby

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DOI: 10.2190/3RTA-83T0-GUFQ-HTME

Abstract

This analysis focuses on the decision-making process of regulating environmental carcinogens as carried out under the Delaney Clause of the Federal Food, Drug, and Cosmetics Act. The study concludes that regulation of environmental carcinogens in this way is unavoidably based upon a relative assessment of risks and benefits, even though the Delaney Clause is commonly believed to preclude such an assessment. The analysis further concludes that by waiting for evidence acceptable to the scientific community before acting, the decision-maker may unknowingly be operating under a relative assessment of risks and benefits not in accord with his or her own perception.

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