Children's Health at Risk

Children today face hazards in the environment that were neither known nor suspected only a few decades ago. At least 75,000 new synthetic chemical compounds have been developed and introduced into commerce. The majority of these have not been adequately tested for their potential toxicity to humans. 
 
The Environmental Protection Agency’s (EPA) cost/benefit approach for assessing children’s health during the permitting process is grossly inadequate and likely to get much worse.
 
As we have seen with EPA circumventing career staff to write much of the cost/benefit analysis for regulating climate change emissions, we can expect to see the same disregard for the public’s health and the environment when EPA reassesses its cost/benefit analysis methodology for children. 
 
There are no valid criteria available for risk assessments for children. As an example, there are figures regarding the projected costs of medical care for the elderly; however, there is nothing comparable for children. EPA does not factor in the costs of air pollution for such things as increasing childhood asthma cases and the almost certain pulmonary damage that will occur in later life.
 
Cumulative risks are not used by EPA. Instead of defining an acceptable risk to each contaminant and discharged or requiring a substitute, EPA grants each chemical a risk level and does not make the effort of calculating the cumulative risk of all chemicals to humans, and seemingly ignores the risks for children.
 
It is no secret that the EPA minimizes regulation so that private corporations can maximize profits (among other things, externalizing costs to the detriment of children). This means we manage risks rather than act on a precautionary principle and prevent what we can. This is further compounded because the EPA uses an inaccurate cost-benefit criterion to evaluate the health risks to children.

Members of EPA’s Children's Health Protection Advisory Committee (CHPAC) should be made up of people who are not self-serving or industry-serving. 

The CHPAC needs to:

1. Correct the failure of the Centers for Disease Control (CDC) to protect children's health by reducing vaccine requirements and requiring universal blood lead level testing for all young children. We continue to express our concern that the CDC, at the direction of acting director Jim O’Neill, fails to protect children's health when the CDC recommends only "high-risk” children be screened for elevated blood lead levels. This lack of screening means up to 40% of children with elevated blood lead levels go undetected.  The number is higher because this does not account for children being exposed to the higher lead levels permitted in soils fertilized with sewage sludge.

2. Correct inadequate standards for lead levels in sewage sludge.  

3. Adopt radon standards, not guides, for indoor air - the most established environmental cause of cancers in children is ionizing radiation. CHPAC needs to recognize the dangers of radon gas and the need to prevent needless exposure to this risk. This risk occurs in Florida, where children live. They are exposed to higher-than-background radon levels from living and attending schools on reclaimed phosphate lands.

4. Require pesticide companies to post a bond to cover damage caused by their products.

5. Require EPA to calculate the cumulative risk of all chemicals in humans.

6. Object to CDC's advisory committee recommendations to reduce vaccine requirements for children. 

Please contact EPA @ https://www.epa.gov/children/forms/contact-us-about-childrens-health and tell them additional protections are needed to protect the health of our nations children. 
Mailing Address:

U.S. Environmental Protection Agency
 Office of Children's Health Protection

1200 Pennsylvania Ave,
N.W.
Mail Code 1107-T

Washington, DC 20460

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