Addressing Chemicals with “Greater Understanding”
June 28, 2013
Statement from Eric Uram, Executive Director of SafeMinds, on improving the Chemical Safety Improvement Act
With growing problems related to childhood health, especially neurological health, federal chemical policy must employ an all-encompassing approach that protects the health of everyone, including future generations. Exposures that affect development, especially neurodevelopment, have been shown to begin even before conception and can result in multi-generational harm by altering an individual's epigenome. The fact that chemical exposures contribute to neurodevelopmental harm is compounded by the recognition that even relatively minor effects on an individual can have profound societal impacts, when the sum of all who are affected is amortized over their lifetimes as a cost to society.
We need to address all chemicals under federal policy with greater understanding. Chemicals must not be put on the market without sufficient knowledge of all their impacts on human health and the environment.
It is the responsibility of the company(s) proposing a chemical's use to establish its safety even before production begins. Different chemicals will have different impacts during various life stages. Thorough understanding of all of these impacts must be a prerequisite. Proof of safety must also take into account variations within the entire population, and especially sensitive populations - those already identified and those we have yet to learn about.
Standards for setting safety levels and determining genetic vulnerability must be clearly defined and adhered to. No situation should allow the use of chemicals without adequate testing unless their needs are clearly spelled out as a national security or public health emergency and approved by governments as such.
Eliminating the backlog of untested chemicals will have to be carried out in an efficient and expeditious manner. And every widely produced and used chemical, including those found in food production – including farm animal feedstock, must be tested for safety as well.
A timeline and priority list for eliminating the most problematic chemicals must be created immediately, and established limits for exposure must be included.
States must remain the incubator for federal policy and should not be limited in their abilities to maintain that status. Variability in local situations must be a consideration under the options available to states when setting policy. No federal policy should preempt the ability of states to act to address their citizens' needs in regards to chemical policy.
When seeking corrections to permitted use, government authority to remove problem chemicals from the marketplace must be well-defined and properly enforced. While education about potential threats can be helpful in reducing exposures, and is part of any regulator's toolkit for public policies, much stronger measures by the authorities need to be deployed where immediate or expedited removal is warranted.