Risk free travel

A supreme advantage of the more general approach is that it introduces explicitly the concept of balance to traffic safety policy. The individual weighing of benefits and costs of additional safety activity is a guide to policy. It explains why attempts to mandate risk free travel are unwise and futile. Risk free travel is an unwise goal because no agen will ever have sufficient power or resources to completely control individual behavior. 

Nonetheless evidence exists that NHTSA seriously entertains this risk free goal. Each year NHTSA prepares a report on its activities under the Vehicle Safety Act. Each year changes in the number of traffic fatalities and in the fatality rate (per vehicle miles) are described. Some years the fatalities and rates are up and some years the fatalities and rates are down compared to 

The individual net benefit approach provides a way of thinking about the costs of pursuing a policy of risk free travel and a way of thinking about a policy risk goal which would reflect social balance. 

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The last known naturally occurring case of smallpox occurred in Somalia in 1977. In May 1980, the World Health Assembly certified that the world was free of naturally occurring smallpox. By the 1960s, because of vaccination programs and quarantine regulations, the risk for importation of smallpox into the United States had been reduced. As a result, recommendations for routine smallpox vaccination were rescinded in 1971. In 1976, the recommendation for routine smallpox vaccination of health-care workers was also discontinued. In 1982, the only active licensed producer of vaccinia vaccine in the United States discontinued production for general use, and in 1983, distribution to the civilian population was discontinued. All military personnel continued to be vaccinated, but that practice ceased in 1990. Since January 1982, smallpox vaccination has not been required for international travelers, and International Certificates of Vaccination forms no longer include a space to record smallpox vaccination. 

So my message to the chemical industry broadly and in particular to the segment of small businesses is to not let the PMN requirements limit your creative spirit in the development and commercialization of new chemicals. The Office of Toxic Substances in EPA stands ready to assist you at no cost in filling out the forms and distinguishing clearly what is minimally essential for risk assessment purposes from what is optional. We have trained consultants in the northeastern and mid-west sections of the country ready to travel to your location and advise you in a confidential way on PMNs. Our staff in Washington can be immensely helpful and you should feel free to discuss your specific situation with them. And, to top it off, we have one recently-retired experienced chemcial industry man concentrating his entire effort to assist the small business man in any TSCA-related matter. His name is Dr. Bob Toomey give him a call on the Industry Assistance Office toll-free line. 

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