| Abstract: | The notions of risk and safety which play a conspicuous role in the regulation of toxic substances have shown a markedly different evolution in France and the United States. American law has moved toward the development of statutory criteria of risk assessment, balancing both the costs and benefits of regulation, while the French legislator has consistently avoided a substantive elaboration of safety concepts through legal texts. This contrast is documented and its implications for the discretionary authority of regulating agencies discussed. Divergent national patterns are explained with reference to four factors distinguishing the legal and political systems of the two countries. |
