A Grave Lapse of Stewardship: Why Pediatricians Need TSCA Reform
January 5, 2012
This essay is in response to: Public Health and the Safe Chemicals Act
Chemical production has increased dramatically in the past half century.
Today, there are more than 80,000 chemicals registered with the EPA for
commercial use. Commercial introduction and wide dissemination of these new chemicals
preceded any systematic effort to assess their potential toxicity. Especially
absent were advance efforts to examine possible impacts on children’s health or
potential to disrupt early development.
Children are most at risk of exposure to the 3,000 synthetic
chemicals produced in quantities of more than 1 million pounds per year. EPA
classes these materials as high-production-volume (HPV) chemicals. HPV chemicals are found
in consumer goods, cosmetics, medications, motor fuels and building materials.
They are detectable in much of the US in air, food, and drinking water.
These chemicals are also finding their way into our bodies. Measurable
quantities of several hundred HPV chemicals are routinely found in the blood
and urine of virtually all Americans (CDC, 2008). Elevated levels of HPV
chemicals are seen also in the breast milk of nursing mothers and the cord
blood of newborn infants (Environmental Working Group, 2005).
There has been a systematic failure to conduct premarket evaluations of
potential toxicity of synthetic chemicals before their introduction to
on potential toxicity is publicly available for only about half of the
3,000 HPV chemicals.
on developmental toxicity or capacity to harm infants and children is
available for fewer than 20% of HPV chemicals (Goldman, 1998).
Phthalates, Bisphenol A, and perfluorinated compounds are examples of
industrial chemicals that became widespread before any assessment of their
potential hazards. They are produced in high volumes, used in myriad consumer
products, and are widespread in children’s environments. Only now, decades
after their introduction, are their possible hazards to children’s health
beginning to be assessed.
This failure represents a grave lapse of stewardship. It puts children
at risk daily of exposure to technologies whose potential for hazard is
virtually unknown. It reflects a combination of
industry’s unwillingness to take responsibility for their products coupled with
failure of government.
The failure of government reflects the failure of the Toxic
Substances Control Act (TSCA). TSCA was intended at the time of its passage in
1976 to be pioneering legislation that would require premarket evaluation of
all new chemicals for potential toxicity. TSCA was also intended to require
retroactive testing of industrial chemicals already in commerce. TSCA never fulfilled
these noble intentions. A particularly egregious lapse was an early decision to
"grandfather in" 62,000 chemicals already
on the market and thus to require no toxicity testing of them. These chemicals were simply presumed safe and
allowed to remain in commerce.
The section of EPA responsible for enforcing TSCA has been
chronically underfunded, understaffed, and overwhelmed by the sheer number of
new chemicals and technologies that come before it. By default, emerging technologies and
new materials have been presumed by EPA to be safe unless there was
overwhelming evidence of their potential to cause harm.
To better defend children against the unforeseen
consequences of chemical exposures, the US needs to adopt a new national
framework and new strategies for responsible stewardship. This new framework
must be designed explicitly to protect children due to their greater vulnerability to toxic
chemicals. A legally mandated,
strictly enforced requirement that all new technologies be examined for
potential toxicity before commercial introduction must be its cornerstone. New chemicals
must be shown to be safe before they are disseminated.
Two other innovations would help protect children from the potential health
effects of chemical exposure:
- Enhanced toxicity testing of
chemicals. Today, most chemicals are tested for toxicity by
administering them to experimental animals during adolescence; the animals are
then sacrificed and examined for toxic effects 12-24 months later. This
truncated approach makes it impossible to study late consequences of early
exposures, and it precludes assessment of developmental toxicity. The duration
of toxicity testing should be extended to incorporate administration of
chemicals in early life -- ideally in utero or even before conception -- coupled with lifelong follow-up (Landrigan et
Epidemiological Studies. Large-scale, prospective epidemiological
studies such as the National Children’s Study are critical engines for
discovering the health consequences of children’s exposures to emerging
National Children’s Study will follow 100,000 children, a statistically
representative sample of all children born in the United States, over a
21-year period from conception to adulthood (Landrigan et al., 2006). The goal is to discover the preventable
environmental causes of chronic diseases of children and then to translate
that knowledge into a national blueprint for disease prevention. Such large-scale
epidemiological investigations have the power to discover new hazards and
to identify critical windows of vulnerability in early development.
Children have been suffering from a lapse of stewardship. But with a
combination of enhanced toxicity testing, prospective epidemiological studies,
and child-protective chemical legislation, such as the Safe Chemicals Act of
2011, we can protect our nation’s future.
This essay is adapted from: American
Academy of Pediatrics Council on Environmental Health. Emerging Technologies
and Materials. In: Etzel, RA, ed. Pediatric Environmental Health, 3rd
Edition. Elk Grove Village, IL: American Academy of Pediatrics; 2012:749-755.
Centers for Disease Control and Prevention National Report on Human Exposure to
Environmental Chemicals. Atlanta, 2001 www.cdc.gov/nceh/dls/report.
Environmental Working Group. Body Burden
— The Pollution in Newborns. A benchmark
investigation of industrial chemicals, pollutants and pesticides in umbilical
cord blood. Washington, DC. Environmental Working Group: July 14, 2005
Goldman LR. Chemicals and children's environment: What we don't know about risks.
Environ Health Perspect 106
Suppl 3:875-80, 1998.
PJ, Kimmel CA, Correa A, Eskenazi B. Children's health and the environment:
public health issues and challenges for risk assessment. Environ Health
Perspect 112(2):257-265, 2004.
PJ, Trasande L, Thorpe LE, Gwynn C, Lioy PJ, D'Alton ME, Lipkind HS, Swanson J,
Wadhwa PD, Clark EB, Rauh VA, Perera FP, Susser E. The National Children's
Study: a 21-year prospective study of 100,000 American children. Pediatrics 118(5):2173-86,