"Education and the Disadvantaged American" represented an attempt by the leaders of the American elementary and secondary education enterprise to come to terms with the failure to learn of a significant portion of the school population. The dimension of race surrounded the discussion leading to publication, but it was never addressed straightforwardly. Rather, the EPC chose to bypass race in favor of various notions of cultural disadvantage or other forms of a cultural deficit model. This choice led not to an effective document, but to a publication that skirted the major issue involved in the situation, race, while being just as negative in its discussion of cultural difference as any racist might be in considering minority races. Sources for this paper include the verbatim records of the deliberations of the Educational Policies Commission, over a two year period as it considered the problem of what to do about non-learners in schools. The eventual document produced and named in the title of this article is another source. The major secondary source for the article is Barry Franklin's "From Backwardness to At Risk," the most scholarly sound history of special education in the USA. Franklin's acceptance of the possible positive result in using the term "at risk" in framing policies for non-learners is called into question, however. He sees at risk as a cultural term but this is precisely how the Educational Policies Commission viewed the term disadvantage. Thus the article concludes that the term "at risk," as used by Franklin and the organizers of ISCHE 29, has the same problematic aspects that severely weakened the EPC publication. (Contains 45 footnotes.)