This model has proven to have serious deficiencies in the environmental protection field where much effort has been spent in developing toxicological dose-response models for chemicals and relatively little on how to make better decisions to address or communicate chemical hazards. Often the assumptions and questions represented in those models have been out of synch with the values of the public that must be addressed or the decisions that public health professionals must make in the real world. In addition, the Initiative seems to vastly overestimate the capacity of local, state, and federal agencies to do risk assessment or to incorporate risk assessments into risk management. The only way to avoid a narrow, regulatory focus that misallocates resources in real public health terms is to keep risk assessment in the context of the decisions that have to be made. The central failing of this section as currently formulated is it manifestly fails to demonstrate a broad understanding of the decisions that public health professionals must actually make in responding to foodborne disease.
More training is needed in risk management generally at all levels of government.
However, risk assessments must be guided by an understanding of the issues that will be important to risk managers and other stakeholders. No attention is paid to this in the Initiative. We fully recognize that risk assessment is necessary in light of current legislation and executive branch policy. However, the Initiative could take a much broader and proactive view of risk-based decision making regarding foodborne illness. There is no public health justification for spending resources solely on risk assessment.