Two Decades of Enhancing Children's Environmental Health Protection at the U.S. Environmental Protection Agency

By Firestone, Michael; Berger, Martha et al. | Environmental Health Perspectives, December 2016 | Go to article overview

Two Decades of Enhancing Children's Environmental Health Protection at the U.S. Environmental Protection Agency


Firestone, Michael, Berger, Martha, Foos, Brenda, Etzel, Ruth, Environmental Health Perspectives


Introduction

Children do not react like adults when exposed to environmental chemicals because their organ systems and metabolic capabilities are not fully developed. Children eat, breathe, and drink more, relative to their body mass, than adults. Their exposures to environmental chemicals differ from that of adults due to child-specific behaviors, such as hand-to-mouth and object-to-mouth activities, crawling on the ground, and breastfeeding. Meanwhile, research shows that exposures to environmental chemicals in homes, schools, food, and common household products may be associated with chronic conditions such as asthma, diabetes, obesity, attention-deficit disorders, learning disabilities, and autism (OUP 2013).

The efforts of the U.S. Environmental Protection Agency (EPA) to enhance consideration of the potential for early-life susceptibility stem from the 1993 National Research Council's "Pesticides in the Diets of Infants and Children" (NRC 1993) and the subsequent 1996 Food Quality Protection Act (FQPA 1996). Twenty years ago, this legislative change to the regulation of pesticides initiated an unprecedented drive by the U.S. EPA to explicitly consider the unique exposure pathways of children versus those of adults. This summer, President Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act (2016), which reforms the 1976 Toxic Substance Control Act (1976) by directing the U.S. EPA to make an affirmative finding on the safety of a new chemical or a significant new use of an existing chemical before it is allowed into the marketplace. These revisions, 40 years in the making, provide a fresh opportunity for the U.S. EPA to further protect children's environmental health by requiring the agency to address unreasonable risks to those who may be the most susceptible including children and pregnant women.

Discussion

Early Drivers for Focusing on Children's Environmental Health

In 1988, when the U.S. EPA attempted to ease restrictions on several pesticides that posed a de minimis cancer risk to humans, the Natural Resources Defense Council brought suit and prevailed. The court stated that only Congress could change the provision designed to protect the public from carcinogens in processed foods and animal feeds in the Food Additives Amendment of 1958, known as the Delaney Clause (Hoyle 1996). Also in 1988, the Congress responded to public concerns about pesticide safety by requesting that the National Academy of Sciences study the issue of vulnerability of children to pesticides residues in foods. The resulting 1993 report "Pesticides in the Diets of Infants and Children" (NRC 1993) made several recommendations for changes in pesticide regulations to protect children's environmental health, including accounting for the unique exposures of children and improving risk assessment methods to estimate the magnitude of the effects of these exposures on infants and children. This NRC report was a principal driver in ultimately elevating awareness among national policy makers of children's vulnerability to toxic hazards, thereby moving U.S. environmental policy toward enhanced protection of children's health and catalyzing research investment (Landrigan 2016). As a compromise to address both the public's concern with protecting children and industry's concern with the inflexibility of the Delaney Clause, the U.S. Congress revoked the Delaney Clause (Appel 1995) and then enacted the FQPA. It was passed unanimously by Congress and then signed into law by former President Clinton in 1996.

The FQPA included a number of provisions to better protect children starting with the use of an additional 10-fold safety factor when setting or reassessing tolerances for pesticides in foods unless adequate data are available to support a different factor. Other provisions that could address potential risk included screening pesticides for endocrine disruption, assessing aggregate exposure from both food and residential uses, and accounting for cumulative exposure to pesticides that have common mechanisms of toxicity. …

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