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Chapter 8

IMPORTANT NEXT STEPS TO PROTECT CHILDREN'S ENVIRONMENTAL HEALTH

REDUCE CHILDREN'S EXPOSURE TO ENVIRONMENTAL THREATS

The most effective way to protect children's health is to reduce, if not eliminate, their exposure to environmental hazards such as lead, pesticides, air pollution, and environmental tobacco smoke. Prevention rather than treatment of disease must be the overarching goal of all efforts to safeguard the next generation. Similarly, pollution prevention is critical to protecting public health.

A number of viable methods exist to decrease children's exposure to environmental toxicants. Alternative pest control strategies exist to dramatically reduce the use of pesticides in agricultural settings, homes, and schools. These methods must be employed more widely. Likewise, technological changes can be made to reduce air and water pollution emission from industrial facilities. Increased transportation efficiency through electric vehicles, low emission vehicles, and improved mass transit will reduce the automotive contributions to air pollution. Smoking cigarettes around children, or even in indoor spaces that children will later occupy, must be stopped. No new sources of lead exposure should be introduced into the environment, and existing sources, e.g., pre-1977 paint, must be cleaned up.

NRDC urges the Administration to set quantifiable exposure reduction targets for specific environmental threats to children's health. These reduction targets should be established for concentrations of pollutants both in the human body and in the environment. The Administration should issue percentage reduction goals for decreasing the "human exposure benchmark," or the concentration of the biological markers for lead, pesticides, air and drinking water pollutants, and environmental tobacco smoke in human blood or other tissue. Where possible, the federal government should also set a goal to reduce the number of people with pollutant loading above a certain level in their bodies. By setting reduction targets for the human exposure benchmark and the number of people with exposure benchmarks above a certain level, the average pollutant concentration in the population should be decreased and the number of people with high concentrations will also be decreased.

For example, levels of lead in blood have declined dramatically in recent years. The government could set a target to reduce the number of children with blood-lead levels over the Center for Disease Control's (CDC) level of concern by 50 percent and to reduce the average of all children's blood-lead levels by 50 percent in the next five years. Through ongoing biological monitoring, the federal government could track its progress toward achieving these goals, and accordingly could channel lead remediation efforts for the maximum benefit. Similar targets for reductions in human exposure benchmarks for pesticides, air pollutants including the constituents of environmental tobacco smoke in human tissue (blood, urine, or breast milk), and drinking water contaminants should be established.

Like the reduction goals for measurements of biological exposure, the Administration should set specific quantifiable environmental improvement goals. These targets would seek to reduce the use or environmental release of certain compounds. For example, the federal government could seek to reduce the number of cities not meeting ambient air quality standards by 25 percent in the next ten years, to decrease overall pesticide use by 30 percent in the next five years, and to reduce the number of reported violations of drinking water quality standards by 25 percent in the next five years. Through ongoing environmental monitoring and data analysis, the Administration could measure whether these targets were likely to be reached and take steps as necessary to ensure the achievement of these goals.

INCREASE THE PUBLIC'S RIGHT TO KNOW

From a position of fundamental fairness, the public has a right to know when it is being exposed to environmental risks. This is the concept behind the Toxics Release Inventory (TRI) established by Congress in 1986. Industrial facilities must annually report to the EPA the quantity of over 600 toxic compounds released into the air or water, onto the land or transferred off site. Each year the EPA publishes a report summarizing these data. TRI has had an important benefit in identifying the pollution loads created by facilities within specific communities.

Another right-to-know approach is embodied in California's Proposition 65, which requires warnings for activities that expose the public to chemicals identified by the state as carcinogens or reproductive toxins. In certain cases the prospect of placing a warning label on a product has led the manufacturer to develop safer substitutes. In these instances, the right to know not only gave consumers the information they deserved but also led to technological innovation.

The right-to-know model is a powerful paradigm for children's environmental health. Adequate data must be generated regarding children's special vulnerability and exposure to hazardous chemicals. But the primary responsibility for developing such data should lie with the entities that manufacture those compounds or the products containing those compounds. The data should be generated promptly and made publicly available in an appropriate form so that the public in general, and parents in particular, can act to avoid unnecessary and involuntary exposures to hazardous compounds.

Warnings should be required under appropriate circumstances, in advance of or even in the absence of regulatory actions under existing federal or state laws in order to allow informed decision-making by consumers in the marketplace. By their nature, warnings impose a lesser burden on affected products than mandatory controls. Therefore, it is appropriate to require warnings at an earlier stage and for exposures at a level that might pose a smaller or less well-characterized risk than that at which mandatory control might eventually be required.

In May 1997, Congressman Henry Waxman (D-Ca.) along with ninety-two co-sponsors introduced the Children's Environmental Protection and Right to Know Act of 1997 (H.R. 1636). Adopting a right-to-know approach, the legislation requires disclosure of high health risk compounds in children's consumer products. The Department of Health and Human Services would issue a list of substances that are carcinogens, neurotoxins, or reproductive toxins. Manufacturers or importers of products with listed substances would report the identity and concentration of the products' ingredients to the Consumer Product Safety Commission. The Commission would then inform the public about toxic ingredients in products.

REVISE GOVERNMENT REGULATORY STANDARDS TO PROTECT CHILDREN

Virtually without exception, federal and state regulatory standards establishing allowable levels of exposure to hazardous substances -- whether they be in air, food, or water -- fail to consider children's unique vulnerability. Until Congress passed the Food Quality Protection Act of 1996, tolerances, or the maximum amount of pesticide residues present in food, were set on the basis of average -- not child -- food consumption rates. The same is true for the maximum contaminant level goals for drinking water and the ambient standards for air pollutants. Moreover, none of the current toxicity testing protocols, the results of which are fundamental to regulatory decision-making, incorporate the equivalent of early childhood exposures. For example, animal tests commence dosing at an age comparable to five or six years in human life.

In August 1996, Congress passed amendments to the federal law regulating pesticide residues in food and required the EPA to revise pesticide tolerances so that children's unique dietary patterns and susceptibility are adequately incorporated.[1] One month later, EPA Administrator Carol Browner announced an agencywide policy that henceforth all regulatory standards issued would explicitly take children into consideration, or state why that was not necessary.[2] In this policy, Administrator Browner committed the Agency to revising five existing standards that do not adequately protect children. Further institutionalizing this commitment to ensure that existing and future regulatory actions adequately incorporate children throughout the entire federal government, President Clinton issued an Executive Order on April 21, 1997.[3]

The Executive Order and the EPA policy are important in further raising recognition of the fact that children are at disproportionate risk from environmental threats such as lead, tobacco smoke, and air pollution. However, until existing regulatory standards are revised to incorporate consideration of children's unique exposure and vulnerability, these administrative declarations will not achieve their intention of protecting children's health. Under the Food Quality Protection Act, the EPA has a legal duty to revise existing pesticide tolerances, or levels of residues allowed in food, so that children are protected. In this instance, if the EPA fails to adequately implement the law, the Agency could potentially be subject to legal challenge. The Executive Order and the EPA policy do not have the same legal force as a federal statute. In April 1997, Senator Barbara Boxer (D-Ca.) introduced legislation (S. 599) establishing that all the EPA environmental and public health standards must protect children and other vulnerable subpopulations with an adequate margin of safety.

Revising existing regulatory standards is essential in order to achieve real protection of children's health. The EPA policy's stated goal of identifying five standards for revision is a good place to start. We urge the Administration to select five standards where children are the least protected within the next six months, to publicly identify these standards, and to commit to a time table for completing the revision of these standards.

IMPROVE RISK ASSESSMENT TO INCORPORATE CONSIDERATION OF CHILDREN

Though no substitute for reducing or eliminating exposure to toxic chemicals, risk assessment is routinely conducted with the intent of quantifying environmental risks. Risk assessment has been rightly criticized for failing to reflect the real world. For instance, risk assessments routinely consider only one route of exposure (e.g., air) to one compound. Moreover, risk assessments to date have for the most part failed to incorporate explicit assumptions about children's differential exposure or susceptibility.

One necessary step in protecting children from environmental risk is improving risk assessment to incorporate thorough consideration of children. In particular, risk assessments for compounds to which children are exposed must be based on children's exposure patterns. Child inhalation rates and food and water consumption rates, must be used. Likewise, risk assessments must include consideration of children's potentially greater susceptibility to any given compound. Data evaluating whether children are more vulnerable to the adverse effects of the particular substance or whether the target organ the chemical potentially impacts is more vulnerable -- e.g., the developing nervous system or brain -- should be available. Existing data on these issues of susceptibility must be incorporated in the risk assessment. In the majority of instances, such data are not available because the standard protocols for toxicity tests do not evaluate the potential effects of early childhood exposures. Therefore, in the absence of sufficient data on childhood vulnerability, a standard margin of safety should be incorporated for data uncertainty. In late February of 1997, EPA Administrator Carol Browner established the Office of Children's Health Protection to serve as a clearinghouse and coordinate research about environmental threats to children's health.

EXPAND RESEARCH ON CHILDREN'S ENVIRONMENTAL HEALTH

In spite of the ever-growing recognition that children are uniquely vulnerable to environmental hazards, research on pediatric environmental health has not been sufficient and should be increased. Without a better scientific understanding of how children are differentially exposed or susceptible to toxicants, our efforts to protect children will not succeed. Though sufficient evidence now exists to warrant immediate action to reduce children's exposure to substances such as pesticides, tobacco smoke, lead, and air pollution, ongoing research is critical both to developing the most effective solutions to these known challenges and to identifying new hazards. Continued and expanded research should be the strong underpinning of efforts on the federal, state, and local levels to rapidly and effectively protect the health of children from environmental risks.

Exposure-Based Research

The two primary questions to be answered by scientific research are: How are children exposed to environmental toxins, and how is children's health affected by those exposures? With regard to exposure, children are generally known to breathe more air, eat more food, and drink more water on the basis of body weight than adults. However, more specific data on children's exposure patterns are needed. Children have a less diverse diet than adults, eating far fewer foods. Dietary diversity increases with age. Yet among the limited existing food consumption surveys, the dietary intakes of children ages one to five are recorded as a group. Because of the changing nature of children's diets, food consumption surveys should include adequate sample sizes of children by one-year age groups, i.e., under 12 months, 13 to 24 months, 25 to 36 months, 37 to 48 months, 49 to 60 months, 5 to 10 years, and 11 to 18 years. This will not only identify differential intake rates but also highlight the foods most frequently consumed by children.

Research documenting levels of chemicals of concern in food, water, air, homes, and schools is also needed to determine how children are exposed. Ongoing environmental monitoring is necessary to identify exposure routes that are hazardous and develop effective interventions.

Another important area for exposure assessment research is monitoring for toxic substances in humans, such as in blood or urine. Such biomonitoring will identify population groups who are at high risk of disease from exposure to toxic substances, and will allow the determination as to whether exposure to specific toxic substances is changing in the population (as occurred with declining levels of lead in blood after lead was removed from gasoline). Research into the development of less costly and simpler methods to measure toxicants like lead is also important so that biological testing can become cheaper and more widely available.

The Agency for Toxic Substances and Disease Registry recently launched a Child Health Initiative to place a special emphasis on identifying the adverse health effects of exposure to chemical hazards at toxic waste sites on infants, children, and youths, and on the prevention of those effects.

Susceptibility-Based Research

In some but not all cases, children may be more physiologically susceptible to the effects of a chemical because their tissues and organs are still developing. Lead, the classic illustration of this, has been the subject of considerable research. More scientific investigation is needed to determine whether other environmental toxicants -- possibly other neurotoxins -- have a greater impact on children than on adults. In addition, research should be conducted to determine whether certain organs in the young child may be more susceptible, such as the brain. Research is needed to identify developmental periods of vulnerability and to study developmental processes during critical periods of vulnerability

Existing toxicity testing protocols must be improved to assess the impact of early childhood exposure. For instance, most animal tests for cancer, nerve damage, or other endpoints do not commence dosing until the animal has reached an age equivalent to five or six years in human life. New screening mechanisms must be established to obtain toxicity testing data that provides useful information on the potential health effects resulting from early childhood exposure.

Funding

New and expanded research on children's unique vulnerability to environmental hazards will require additional funding. With increasing public concern about children's environmental health and the current Administration's commitment to protect children as evidenced by President Clinton's April 1997 Executive Order, increased research funds should become available. However, this increase should not come at the expense of other human health or environmental research projects. We absolutely must increase the size of the research funding pie, not just slice the pie differently.

One possible source of funding could be a voluntary donation toward research from members of the public through a routine activity such as the purchase of postage stamps. Consumers could have the option of buying a regular-priced postage stamp or paying one penny more per stamp with the additional cent going toward a pediatric environmental health research fund. Breast cancer activists are considering this option for increased research funding. This approach is already used in a number of states through the offering of specialty license plates for higher motor vehicle registration fees, with the difference in fees going to special state projects such as parks.

EVALUATE COMMUNITY PROGRAMS TO PROTECT CHILDREN'S ENVIRONMENTAL HEALTH

Strong federal laws and regulations are necessary to protect children from environmental toxicants such as lead, pesticides, and air pollution. However, additional nonregulatory local efforts are equally important, and in some cases more politically feasible. Citizens can have a significant impact on establishing programs in their local communities to reduce children's exposure to environmental threats.

One way to get started is to conduct a survey of your community to determine whether it has taken adequate steps to safeguard children's health. It may take some time to determine which level of government and which agency is responsible. For example, does the county or town regulate septic systems? Are pesticide issues handled by the environmental department or the health department? In order to get a complete understanding of your community's efforts, you may have to call more than one level of government and more than one department. Be prepared to ask the same questions of each agency. Here is a list of sample questions:

Lead

  • Does your community have a lead poisoning prevention program? Does your community test houses for lead hazards for free? Does your community water supplier test home tap water for lead? How many staffers and how much budget does your community's lead poisoning prevention program have?
  • Does your community have funds to help private property owners pay for control of lead paint hazards?
  • Does your community routinely screen children for lead?
  • Do children in your community have levels of lead in their blood in excess of the CDC's level of concern? If so, how many?
  • Are the schools, daycare facilities, playgrounds, and other places young children frequent in your community lead safe?
  • Were more than 25 percent of the homes in your community built prior to 1950?

Air Pollution

  • Does air quality in your community exceed federal or state air quality standards? How often?
  • What are the staff levels and annual budget for your community's air quality program? Have any enforcement cases been brought against violators in the last several years? If so, how many?
  • Does your community have a program to alert citizens when air quality becomes unhealthy? Is it adequate? How is the community alerted?
  • Does your school have possible alternative activities to outdoor physical exertion during air pollution episodes?
  • Does your community have a program to prevent significant deterioration of air quality?
  • Does your community have an ongoing smog check program for inspection and maintenance of vehicle emissions?
  • Does your community encourage alternatives to automobile use? Is the public transit system sufficient?

Pesticides

  • Are pesticides (insecticides, herbicides, fungicides, and rodenticides) used in your community's schools, daycare facilities, parks, or public buildings? Which pesticides are used and in what amounts?
  • If they are used, is the public adequately notified before and after their application?
  • Does your community have a policy to reduce pesticide use such as a biologically-intensive integrated pest management policy? If so, what type of a program? Does it have paid staff, and what is the annual budget?

Environmental Tobacco Smoke

  • Does your community have a program to educate citizens of all ages about the hazards of cigarette smoking and secondhand smoke? If so, how is the education conducted? Is information distributed? If so, how much, to whom, and of what type?
  • Does your community prohibit smoking in public facilities such as government buildings, public schools, and government daycare facilities?
  • Is smoking allowed in the private property spaces you and your family frequent such as restaurants, schools, and malls?
  • Does your community have programs to help smokers quit?

Drinking Water

  • What contaminants may be present in your drinking water? When was the water last tested? How frequently is it tested? How many samples are collected annually? From where are samples collected?
  • What is the source of these contaminants?
  • Does your community have a program to protect drinking water quality, such as a watershed protection program? If so, what type of a program? What are the staff levels and annual budget?

If government staff cannot answer these questions, ask your local elected officials. The preceding chapters include examples of successful measures taken by communities to protect children from environmental threats. If your community is not doing enough, you can get involved in the effort to better safeguard children.


Notes

1. Food Quality Protection Act of 1996, Pub. L. No. 104-170, 110 Stat. 489 (August 3, 1996).

2. EPA, Environmental Threats to Children's Health, September 1996.

3. Executive Order 13045, "Protection of Children From Environmental Health Risks and Safety Risks," April 21, 1997.

last revised 11/25/1997

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