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Letter to Stephen Johnson, Administrator of the Environmental Protection Agency, Re: Maintain Child Health Protections In Controlling Cancer Risks

Letter

By:
Date:
Location: Washington, DC

Boxer and Clinton Call on EPA to Maintain Child Health Protections In Controlling Cancer Risks

Current EPA Proposal Weakens Safeguards for Children

Senator Barbara Boxer, Chairman of the Senate Environment and Public Works (EPW) Committee, and Senator Hillary Rodham Clinton, Chair of the EPW Subcommittee on Superfund and Environmental Health, today called on the Environmental Protection Agency (EPA) to reverse its plan to weaken safeguards for children when the agency uses its Cancer Risk Guidelines, even though children often face greater risk of adverse health impacts from cancer-causing toxins. In a letter to EPA Administrator Stephen Johnson, Boxer and Clinton underscored that EPA's proposed plans go against the recommendations of its independent scientific advisors, its children's health advisory committee, and other scientific and health experts.

Senator Boxer said, "It is outrageous that the Environmental Protection Agency would even propose weakening cancer protections for children. It is time for the EPA Administrator to listen to his own scientific advisors and put the health of America's children first."

"It is unconscionable that the EPA would even consider lowering safeguards that protect children from dangerous carcinogens. Protecting children's health must be paramount and we urge the EPA to stop this shortsighted plan," said Senator Clinton.

Senators Boxer and Clinton have been active in working to improve children's environmental health and ensure that the EPA addresses the health impacts of those disproportionately burdened by environmental pollutants. Last year, Senators Boxer and Clinton requested that the Government Accountability Office (GAO) investigate the extent to which EPA incorporates and utilizes the recommendations of the Children's Health Protection Advisory Committee - the body of experts designed to help EPA ensure that the interests of children are represented in the agency's activities. Senator Clinton has also introduced legislation to help decrease exposures to the environmental pollutants linked to childhood illness, including lead poisoning and asthma.

The text of the letter follows:

February 20, 2008

The Honorable Stephen Johnson
Administrator
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC

Dear Administrator Johnson,

We urge the Environmental Protection Agency (EPA) to ensure that its Cancer Risk Guidelines include a built-in margin of additional safety for children, as has been repeatedly recommended the agency's independent scientific advisors, its children's health advisory committee, and other scientific and health experts.

Scientific experts have a long history of highlighting the need for lower thresholds of exposure for children. In 1993, the National Academy of Sciences (NAS) released a landmark report, that noted "children are not little adults," and can be far more vulnerable to the effects of certain toxic chemicals than are adults. In addition, it stated, "for certain chronic toxic effects such as cancer, exposures occurring early in life may pose greater risks than those occurring later in life." Over a decade later, the NAS reaffirmed the importance of recognizing the particular risks facing children, declaring: "[I]t is in our national interest to place a higher priority on children's health." Children have rapidly developing bodies and small exposures to harmful substances can disrupt delicate developmental activities during early life. In addition, children may metabolize substances in a manner different from adults, and exposure to hazards can cut short a child's life or cause dramatic and life-long health effects including cancer.

In light of mounting scientific evidence, Congress passed the Food Quality Protection Act in 1996 to require EPA to set health-protective values for children, plus an additional margin of safety for unique sensitivities, including the heightened vulnerability of children. In the same year, Congress amended the Safe Drinking Water Act to require EPA to give children and vulnerable populations special consideration when setting drinking water standards. And the following year, President Clinton launched Executive Order 13045, which requires EPA to "ensure that [its] policies, programs, activities, and standards address disproportionate risks to children that result from environmental health risks…."

EPA has issued a number of draft guidance documents that describe how the agency will analyze risks from cancer-causing chemicals under its 2005 Cancer Risk Guidelines. We are concerned that one such document, titled "Framework for Determining a Mutagenic Mode of Action for Carcinogenicity," will lead to the elimination of an added margin of safety to protect children when EPA is assessing many cancer-causing substances. Under this Framework, EPA proposes to use an additional margin of safety only in one very limited case, where EPA knows that a specific process causes cancer. EPA admits this is "a very limited" definition.

EPA's proposed approach has the potential to seriously weaken children's health protections. In 1994, the NAS explained:

EPA's practice appears to be to allow departure [away from using an additional margin of safety] in a specific case when it ascertains that there is a consensus among knowledgeable scientists that the available scientific evidence justifies departure from the default option…We believe that "the agency must continue to rely on its Science Advisory Board (SAB) and other expert bodies to determine when departing from a default option is warranted…

Both the SAB and EPA's Children's Health Protection Advisory Committee have recommended that EPA generally retain the margin of safety. When EPA began developing these current guidelines, the SAB specifically noted that "...the primary goal of EPA actions is public health protection and that, accordingly, as an Agency policy, the defaults used in the absence of scientific data to the contrary should be health protective." As part of its evaluation of the Guidelines in 2004, the SAB urged EPA to "reconsider the decision not to apply" the added margin of safety to protect children from chemicals that cause cancer by an unknown mechanism. EPA's actions appear to run contrary to the SAB's recommendations for protecting children's health.

In 2007, EPA's Children's Health Protection Advisory Committee sent a strongly worded letter opposing the agency's proposed approach. The Committee found numerous problems with the Framework, including that it creates "the potential for inconsistent and arbitrary decision-making…[and that it] creates a disincentive to new data generation…" The Committee recommended that EPA "redraft the Framework" using the Committee's views.

We cannot stress enough the importance of ensuring that children are considered in all the agency's work in developing and implementing standards to protect against the risks of carcinogens and other pollutants. This Framework falls short of meeting that goal. Please describe EPA's plan for integrating the views of its science and children's health expert advisors into the Cancer Risk Guidelines by February 25, 2008.

Sincerely,

Barbara Boxer
Hillary Rodham Clinton


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