Misuse Of Regulatory Upper-Bound Risk Characterizations:

            Plaintiff experts and others frequently misuse regulatory risk characterizations and regulatory cancer slope and potency factors.  The misuse stems primarily from their failure to recognize and clearly state that the "calculated risks" do not necessarily give a realistic prediction of risk and that the true value of risk may be as low as zero.

In the U.S. EPA's 1986 guidelines, EPA's regulatory upper bounds are described as "...a plausible upper limit to the risk that is consistent with some proposed mechanisms.  Such an estimate, however, does not necessarily give a realistic prediction of risk.  The true value of risk is unknown, and may be as low as zero."