For the current paper, the charge from the oil shale task force was to critique the Hicks and Probstein paper, emphasizing where we agree and where we disagree with the themes, concepts, data, and conclusions offered. In our effort to constructively criticize, we will also review data on the toxicity of untreated and treated oil shale wastewater streams and suggest an alternative to or, more precisely, an adjustment in the risk analysis strategy proposed by Hicks and Probstein.