SECTION: CAPITOL HILL HEARING TESTIMONY

LENGTH: 5987 words

HEADLINE: TESTIMONY May 02, 2000 DR. J. ROUTT REIGART CHAIR OF THE ADVISORY BOARD CHILDREN S ENVIRONMENTAL HEALTH NETWORK HOUSE APPROPRIATIONS LABOR, HEALTH AND HUMAN SERVICES, AND EDUCATION LABOR HHS APPROPRIATIONS

BODY:
Children's Environmental Health Network Testimony before the Subcommittee on Labor, Health & Human Services, Education and Related Agencies House Committee on Appropriations Informational Hearing on Children's Environmental Health May 2,2000 Thank you for the opportunity to testify before this subcommittee in this special hearing. I am Dr. J. Routt Reigart, chair of the advisory board of the Children's Environmental Health Network. I am Professor of Pediatrics, Director of General Pediatrics at the Medical University of South Carolina and I also serve as chair. of the Children's Health Protection Advisory Committee of the U.S. Environmental Protection Agency (EPA). In addition to participating on a number of scientific advisory panels for EPA and the Department. of Health and Human Services, I served as chair of the American Academy of Pediatrics' Committee on Environmental Health from 1991 to 1995. The Children's Environmental Health Network is a non-pardsan and multi-disciplinary national project whose sole mission is to protect the fetus and the child from environmental hazards and to promote a healthy environment. The Network's Advisory Board and committee members include numerous experts in children's environmental health science and policy who serve on key Federal advisory panels and scientific boards. We commend this subcommittee for bringing attention to the issue of children's environmental health. I would especially like to recognize the outstanding leadership on this topic provided by Chairman Porter and Congresswoman Pelosi. You have both sustained your early and on-going dedication to understanding this topic and bringing it to your colleagues in Congress, and we thank you. The last few years have seen a dramatic increase in awareness of the simple fact that children may be harmed by a wide range of environmental toxicants - often in ways quite dissimilar to adults. For example, a 1997 report that found a relationship between certain air pollutants and infant mortality received wide coverage. Yet much more needs to be done in educating the public, amending our policies and gaining more information if we are to meet the challenge of providing a healthy environment and protecting our children from environmental risk. I'd like to highlight a few of the basic medical and scientific concepts that form the foundation for this field. A fundamental maxim of pediatric medicine is that children are not "little adults." What does this mean when we talk about children and environmental toxicants? Scientists have documented the many differences between adult and child behavior and exposures; often these differences lead to higher exposures for children. The medical evidence is unassailable that every child experiences particular windows of vulnerability from conception through adolescence. Exposure at those moments of vulnerability to environmental hazards can lead to permanent and irreversible damage. In brief, children can be more susceptible to harm caused by environmental agents. Exposures that for an adult may have little or no consequence can result in life-long harm for a child. There is clear, sound science underlying these principles. There is a solid consensus in the scientific community for these concepts. As additional scientific knowledge in this field expands, it continues to reinforce this foundation. For additional background, I would like to submit for the record materials that the Network developed for a Congressional briefing last year. What I would like to focus on in my testimony today is what these medical and scientific principles mean and how they call for important changes in many aspects of our society - changing our societal priorities to put children's health and safety at the center of the decision making process. My testimony seeks to provide an overview of changes to be made within the purview of Federal, state and local government that would indeed shift the paradigm and reflect the science, so that we move toward our goal of protecting all children. Policy Changes Today, the predominant assumption in the regulatory approach to environmental protection is that potential hazards are innocent until proven guilty. While there are still questions to be answered - and there will always be more questions to answer - existing medical and scientific knowledge already tells us that the current system is failing our children, putting them at risk. Waiting for certain evidence of harm means that a generation or more of children would be placed unnecessarily at risk of life- long, irreversible damage. We must act to prevent potential harmful health effects due to environmental health hazards. We need a commitment to review and change our policies to protect children. Obviously, past practices that do not take children s vulnerabilities and exposures into account cannot be assumed to be protective of children's health. Since the windows of vulnerability that children experience as they grow do not exist for adults, standards based on effects on mature systems will not take into account children s vulnerabilities. Since children's exposures to environmental toxicants are not the same as adult exposures, adult exposure estimates cannot be extrapolated to estimate children's exposures. Because of a variety of factors, such as children's hand-to-mouth behavior and the additional time children spend on carpeting and floors, estimates based on adult exposures are likely to understate children's exposures. Yet current legislation, regulatory standards, health risk assessments and other risk-based policies do not adequately address this unique population and its vulnerabilities. Our traditional approaches have been to use a one-size-fits-all template, and that template is usually the healthy adult male. Our policies must replace the traditional assumptions in our science and our standards that the population is homogeneous, adult, healthy, white and male with more realistic assumptions reflecting the diversity of our population. These assumptions must be designed to protect children and other vulnerable subpopulations. We must specifically consider children and how their behavior, environment and diet differ from those of adults. Additionally, our policies must recognize that not all children face the same hazards. We must seek especially to protect those most at risk - including poor children, minority children, and farmworker children. Many children are living in communities disproportionately impacted by environmental exposures; our policies need to provide adequate protections for these children - for all children, not-just some children. Our policies need to reflect the real world. In the real world, children are exposed to more than one chemical at a time. In the real world, exposures come from more than one source and one chemical. Yet, in the policy and regulatory world, these realities are often ignored in favor of unrealistic assumptions - one chemical exposure at a time, one route of exposure, no mixture of chemicals, and no additive or synergistic effects of different chemicals. These assumptions work against assuring a safe and healthy environment for our children. Parents and other caregivers have the right to know what their children are exposed to, and our policies should reflect that right. Our children will not be protected by governmental policies alone. Parents have the responsibility to protect their children from environmental toxicants. But a parent cannot meet this responsibility if they do not know what chemicals are present in their community, in schools, parks, and public spaces, in the food, air and water their child ingests, or in the products they bring home. Without that information, parents can not know what their child's potential exposures are, what the possible health effects of an exposure may be, and what alternatives and options for action exist. Both implicitly and explicitly, we need to improve how we value children. Traditionally, we have not adequately recognized the moral and societal special value that we claim to place on children when we are setting policies that affect their health and future. The assumptions of traditional cost-benefit assessments - e.g. that the future should be steadily discounted or that a person's value can be adequately measured through wages earned and goods purchased - do not reflect the stake we all have in assuring the health and safety of generations to come. These assumptions underrate the benefits of prevention, especially the prevention of long-term or subtle health effects. Children are our future - and so we need to more accurately measure the true value of that future if we are to set wise, protective policies in place. Research, Medicine and Public Health Additional research is desperately needed on both children's exposures and on the health effects on developing systems resulting from exposure to toxicants. We need to better understand the real world our children live in and the substances to which they are exposed. Research is needed to obtain more information on environmental hazards facing children, including patterns and pathways of children's exposure. This inform on, once developed, must be incorporated in regulatory decisions, exposure and risk assessments, and other policies. We strongly support the excellent work being done by the Centers for Disease Control and Prevention's National Center for Environmental Health (NCEH), especially the NCEH's efforts to continue and expand its biomonitoring program and to establish a national report card on exposure information. Biomonitoring efforts such as theirs are an important part of the data that must be collected to understand children's exposures. We must also do a much better job tracking the occurrence of diseases that may have an environmental component. For example, few states have asthma registries or adequate birth defect registries, so we cannot even properly measure the occurrence of these health effects in our population, much less see if they are increasing or decreasing in certain areas or among certain populations. We cannot see where we are going, or make progress toward our goals, if we do not known where we are. We need to set measurable goals to decrease the incidence of health effects such as these, which cannot be done until we first set goals to measure incidence. For example, we need a set of clear pediatric environmental health objectives in our national Healthy People program. We agree with the recommendation of the Pew Environmental Health Commission that more attention and resources must be paid to our basic public health infrastructure. This is an area where policy, research and medicine all have a stake. The cadre of health care professionals with expertise in pediatric environmental health must increase. While important, yet isolated, education opportunities exist and as pediatric and public health disciplines work to educate their communities - such as the American of Academy of Pediatrics' 1999 release of the Handbook of Pediatric Environmental Health - government support for fellowships in this field will accelerate the creation of a diverse, populous group of experts for this growing, demanding field. We need to better understand how children's systems respond to chemical exposures and the resulting health effects, and how these responses differ from those of adults. For example, studies of causes of cancer in adults will not replace studying the causes of cancer in children. We cannot simply extrapolate from one to the other. A major longitudinal cohort study has been proposed to help provide exposure and health effects information of the type I have described. The Network supports undertaking appropriate studies to determine the feasibility of this ambitious project. If a study can be properly framed and adequately funded, it has the potential to provide valuable, much-needed information. This project should be conducted as a joint project with the U. S. Department of Health and Human Services and the U.S. EPA. If we are to adequately understand children's susceptibility to environmental hazards, research will play a key role in expanding this understanding. The research and studies which are needed include, but are not limited to, field studies and epidemiological research. These types of research must be supplemented and supported by the appropriate laboratory research. We believe that such laboratory experimentation is extraordinarily important to fill gaps and provide vital information. Such additional research and tests often call for the use of laboratory animals. Some organizations have strongly opposed all research that involves animal testing. Of course, the Network opposes any unnecessary or inhumane use of animals and supports the use of validated methods that produce adequate scientific information while reducing or eliminating use of animal testing. However, appropriate animal testing is necessary if we are to adequately understand the impact of a chemical exposure on children's health. Not performing the necessary tests in a laboratory setting means that we are testing - in an unscientific manner - a chemical in our children. Using children as "canaries" to identify hazardous chemicals is unacceptable and immoral. Regulation and Standard-setting Those who introduce chemicals into the environment should be held responsible for conducting studies adequate for fully understanding children's potential exposures to the chemical and the potential health effects for children. And we must regulate based on this information, not based on information that is extrapolated from adult exposures and adult toxicology. Studies conducted for the purpose of setting standards for a chemical typically focus on mature systems. Chemicals are not tested for long-term effects resulting from very early in life exposures to developing systems. Nor do we look for sensitive, yet important health outcomes, such as impacts on learning, memory, or behavior. Protocols for testing batteries and exposure assessments must be improved to explicitly consider these key factors. As just one example, the nervous system is arguably one of the most delicate and vulnerable human systems. The disruption of any one of the many vital steps necessary for a healthy brain and nervous system by environmental agents can result in permanent injury or impairment. Although many pesticides are designed to work by harming the nervous system of their target, pesticides' impact on the developing nervous system is not a part of the required testing for registration of pesticides. When the U.S. Environmental Protection Agency was reviewing organophosphate pesticides last year, a class of more than 40 neurotoxic pesticides, many of which have been in use for decades, the agency had developmental neurotoxicity information on only 12 of them. Our goal should be to prevent exposure to any chemical for which adequate information on potential health risks to children is not publicly available. Rather than simply assuming their safety, we should prohibit new chemical compounds from use in commerce or release in the environment until they are adequately tested for safety to children. Neither should we assume that chemicals already in use pose no threats to children - and so the prompt development an public availability of the necessary child- specific health effect and exposure information for these chemicals must be required. While we are developing the additional research and data needed to provide the best possible guidance for adapting our policies, regulations, and standards to adequately protect children, we cannot stand still. Until we have more complete guidance, our policies must be sufficiently conservative to provide assurances that we are acting cautiously to protect our children. We must err on the side of protecting our children, not on the side of the chemical. The National Academy of Sciences (NAS), when reviewing Federal pesticide regulatory policy, said, for example, that "In the absence of data to the contrary, there should be a presumption of greater toxicity to infants and children." The NAS recommended the use of a ten-fold safety factor in setting permissible pesticide residue levels in cases such as the absence of full toxicology data relative to children. Using similar safety factors makes sense in other regulatory venues. Existing Policies and Activities We have been heartened to see the Federal activities and programs underway that seek to better understand children's environmental health and to implement protections for children from environmental toxicants. In addition to the NCEH's efforts mentioned earlier, the Agency for Toxic Substances and Disease Registry, the National Institute of Environmental Health Sciences, and the EPA have undertaken initiatives on this topic. The EPA created an Office of Children's Health Protection, which has done excellent work inside and out of the agency to bring the concerns of protecting children to the forefront. One of the Network's concerns is that this office is scheduled to sunset in 2002; the Network and others are urging EPA to extend the office until a series of key goals are met to better assure the protection of children in EPA decision-making. The Network was extremely pleased by the establishment of an Interagency Task Force on Environmental Health and Safety Risks to Children, co-chaired by HHS Secretary Donna Shalala and EPA Administrator Carol Browner, to recommend strategies for better addressing children's environmental health and safety within the Federal government. This task force is - laying an important role in addressing a key concern of ours, which is to assure that the Federal agencies and offices working on this important issue coordinate and cooperate on their efforts, so that the nation's resources are focused and leveraged to assure the most effective use of these resources. The task force helps to provide this focus and meet this concern. Such cooperation is key not only in terms of policy, but also in setting research priorities, since key research is being conducted by over half a dozen difference federal agencies, task forces, and institutes (e.g. EPA, HHS, NICHD, HRSA, ATSDR, CDC, NIEHS). Such research has yielded wide- ranging results from safer cleanups of toxic spills to pollution prevention to treatment of environmentally-related illnesses to fundamental research on body systems and chemical uptake - and yet it faces far too many financial constraints. The Network hopes the task force will continue to play a key role in promoting communication and cooperation for the foreseeable future. It is also encouraging to see the cooperation between the EPA and NIEHS in establishing Centers of Excellence in research in children's environmental health around the nation. Eight centers have been established, pursuing a variety of important research questions in a diverse array of communities and populations. However, aside from these few examples, the science of children's environmental health is generally not reflected in governmental policies or activities, as I described above. If we are to serve our children well, this must change. The single greatest policy advance in recent years in protecting children from environmental toxicants was Congress' unanimous adoption of the Food Quality Protection Act (FQPA) in 1996. The FQPA statute reformed pesticide regulation in response to a 1993 NAS report finding that the then-current pesticide regulatory framework did not provide adequate health protection, especially for children. - FQPA makes health protection the basis by which pesticide regulatory decisions are to be made and places a high priority on protecting children's health. Under FQPA, key factors which had not previously been considered in setting pesticide tolerances (or allowable pesticide residue), such as accounting for non- dietary sources of exposure and children's unique susceptibilities, are to be considered in the regulation of pesticides. If the, EPA does not have pesticide-specific data on health effects on developing systems, FQPA directs the agency to act promptly and conservatively by setting the pesticide's allowable residue in food at levels that assure protection of children's health, rather than maintaining the status quo. This approach better assures that we are protecting children while it also encourages more rapid development of chemical-specific data. The alternative is to allow children to be exposed to higher level of pesticides while waiting years for "proof of harm (to children's brains nervous systems, behavior, learning, rates of cancer, etc.). Under FQPA, when regulating a pesticide, the agency is required to include an additional ten- fold margin of safety for protecting children. This safety margin can be changed only if the agency has "reliable data7' that doing so "will be safe for infants and children." The FQPA is a monument to our commitment to protecting our children, and a strong sign that the paradigm not only can change, but also is changing. The FQPA lights the way for the wide array of the needed policy and regulatory changes I outlined earlier in my testimony. The very worst thing that we could do would be to repudiate this landmark legislation and the concepts that underlie it. We need to uphold the rare existing policies - such as FQPA - that specifically take children into account. Yet, legislation that would essentially repeal this vital health-based statute has been introduced in both the House and the Senate and has been cosponsored by many Members of Congress. We are deeply concerned at the apparently large support in Congress for gutting this scientifically sound and child- protective law. FQPA puts children's health first. This repeal legislation, H.R. 1592 and S. 1464, would essentially assure that no pesticide regulation would be set to be protective of children's health. It would delay protective action indefinitely as industry is given time to develop data while the current, less- protective regulations remain in place. It also provides no incentive to develop additional data while providing ample opportunities to instigate legal action against pro-safety decisions. Under these bills, U.S. children would be exposed to higher levels of pesticides for years longer than FQPA would at present allow. If Congress is truly interested in protecting the health of our children, it will not move forward with undermining the Food Quality Protection Act. We commend you for the leadership you have shown by holding this hearing. We hope the testimony you have heard here will move you and your colleagues to take the actions necessary to protect our nation's children. Again, thank you for the opportunity to testify.

LOAD-DATE: May 16, 2000, Tuesday