A Collaborative Effort to Protect Public Health: The Work of the National Conversation on Chemical Exposures

The National Conversation on Public Health and Chemical Exposures was initiated by the Agency for Toxic Substances & Disease Registry and the Centers for Disease Control and Prevention in June 2009 to make a plan to better protect the public from harmful chemicals. The National Conversation, as it’s called, works to engage people concerned about chemical exposures and public health in order to develop strategies and ideas on how to use and manage chemicals safely.

Kristen Welker-Hood, PSR’s Director of Environment and Health, was a member of the “Policies and Practices” working group. That group focused on improving public health through a more proactive, preventative approach. The three levels of public health prevention are:

1. Primary prevention – Preventing harm by eliminating and/or reducing the production or use of harmful chemicals and by spurring the development and diffusion of safer and healthier alternatives.
2. Secondary prevention – Addressing harm by eliminating and/or reducing exposures to harmful chemicals.
3. Tertiary prevention – Addressing harm caused by historic practices, by protecting the health of at-risk populations and contaminated communities.

The Policies and Practices workgroup offered recommendations to shift the approach of federal and state chemical management policies and programs from one of secondary or tertiary prevention to one of primary prevention. Exhibit A: the Toxic Substances Control Act (TSCA), enacted in 1976. This act has the intent of protecting the public from harmful toxins by regulating chemicals in commerce, but in reality lacks the muscle to be a proactive, preventive legislation.

Under TSCA, chemicals regulated under the EPA cannot be restricted or banned until the Agency first proves that the chemical is hazardous. It’s an almost impossible task, because there are few requirements for safety testing of new chemicals. Furthermore, when the statute was enacted, more than 60,000 chemicals were grandfathered in for approved use. A scant few of these grandfathered chemicals have had completed screens for human safety. Moreover, companies that manufacture and/or use the chemicals in their products are able to deny the public and EPA access to information regarding those chemicals by claiming that it is classified business information. Due to these limitations, TSCA cannot proactively protect people from harmful chemicals. In order for TSCA to exemplify the goal of primary prevention, an extensive overhaul is necessary.

I attended the recent National Conversation Leadership Council Meeting. The Leadership Council consists of 40 experts in public health and environmental fields. Its main function is to create an Action Agenda, a document with clear and achievable steps that organizations and agencies can take to better protect the public from harmful chemicals. Although most of the discussion at that meeting focused on specific wording of the text or the order of recommendations, the debates over what some may consider “minute details” are a direct reflection of how important the document is to the members of the Leadership Council. They want to make sure that legislators, regulators, and industry members find the recommendations relevant, important, and achievable. 

The Action Agenda, once finalized, could prove to be very powerful. It outlines the steps that government agencies can take in order to strengthen public health mandates already in place while working towards protecting more people from toxic chemical exposures. By reaching a consensus on the recommendations, it assures those receiving the recommendations that these ideas are not just the concerns of a few individuals but a culmination of views from a large group of stakeholders across the United States. The recommendations were crafted to be broad enough to allow some flexibility on how the agencies and government bodies can apply them, but to remain specific enough to keep the focus on primary prevention.

One concern I had was that some the recommendations should be stricter; one of the points that came up at the meeting of the Leadership Council was that the recommendations to industry and private companies used the word “require,” while those to federal and state agencies did not. Those recommendations instead used the words “encourage” and “promote.” Although in terms of chemical management we have witnessed that when language suggests “voluntary” as opposed to “required” action to control exposure or provide safety information, producers have raced each other to the bottom rung of health protections, as in the case of EPA’s High Production Volume Chemical Assessment and Management Program (ChAMP). Without strong recommendations from the Leadership Council, I can foresee further delay in our efforts to proactively protect the public. Strong recommendations would better protect public health, given the inevitable compromises by agencies and private corporations in the implementation of chemical regulatory policy. However, the council felt that presenting their recommendations as “requirements” would cause people to automatically dismiss the feasibility of the recommendations; therefore the wording was revised. 

The Leadership Council will release the final draft of the action agenda this month. All aspects of the National Conversation can be accessed here.

Shoko Kubotera is the Environment and Health intern at Physicians for Social Responsibility. She completed her undergraduate degree at Binghamton University (State University of New York) and is currently exploring opportunities in the public health field with hopes of attending graduate school in public health.

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