F the EPA

you thought testing on animals was morally bankrupt, just wait until I tell you what villainous schemes the Environmental Protection Agency, with the aid of the world’s most powerful chemical corporations, have been cooking up. In the effort to maximize profits at the expense of human welfare, these supposed protectors of health and environment have drafted a flowery new piece of legislation that “significantly strengthens the ethical framework” of studies conducted by the Agency . What is it, you ask?

Testing toxic pesticides on human children. In some cases, without consent.
Last August, Congress mandated that the EPA create a rule that permanently banned chemical testing on pregnant women and children, “without exception.” This was specifically in response to an EPA study entitled Children’s Environmental Exposure Research Study (CHEERS). This study was cosponsored by the EPA and an organization called the American Chemistry Council (ACC). Formerly known as the Chemical Manufacturer’s Association (CMA), the ACC charter reads like a who’s who of the world’s producers of toxic chemicals, including Dow Chemical, DuPont, Exxon Mobil, Proctor & Gamble, and Monsanto.

For a little less then $1,000, a free camera, and a t-shirt, low-income families, under the CHEERS program, could sell their children to the study for two years. The program included deliberate dosing of children with pesticides known to be dangerous, in order to monitor their responses.

Hailing itself as a “landmark regulation on human studies,” the new rule begins by proclaiming that it will “categorically prohibit any intentional dosing studies performed on women or children,” but in the following 30-odd pages of fine print, it contradicts itself more than a few times. Some of the loopholes available include permission to conduct testing on (brace yourself):

-Neglected and abused children, for whom consent is not necessary.
-Children who “cannot reasonably be consulted,” such as those who are mentally handicapped, as well as orphaned newborns. For these children, consent is deferred to the guardian or institution in charge of them. Often, these are cash-strapped orphanages who will do almost anything to keep their institution open.

-Tests conducted outside of the United States. -Tests that include ”crucial” research.

Unfortunately, the EPA sets up no criteria to determine what is “crucial,” opening a potentially limitless loophole. As if the situation wasn’t bad enough, little to nothing will be weaned from the experiments. Two years is hardly enough time to monitor the full effects of pesticide exposure, which include retarded development, susceptibility to cancer, early puberty and hormonal disruption, and birth defects in children.

The ACC is not spending millions of dollars sponsoring this rule because of its concern for the well-being of the children. Rather, they know that the insufficient data will portray these chemicals in a positive light, even though extensive testing has already been done to show that they are dangerous. Unfortunately, these existing studies have routinely been ignored or buried by the ACC and EPA.

A CMA internal memo obtained in 1992 outlines the industry’s intentions in cooperating with the EPA. According to the memo, it allows them to “appear willing to develop information on industrial chemicals” while “strengthening the industry’s advocacy position with the EPA.” In other words, the $2.2 million given to the EPA for this new study is anything but “no strings attached.” The ACC will also have an opportunity to “review” drafts of the study before its release. Although this is certainly a huge step back for ethics in science, it is not an isolated incident. Back when it was known as the CMA, the ACC was found guilty of manipulating data in studies in order to show toxic chemicals to be safe. Since then, the ACC has been involved in blocking laws that would prevent the use of arsenic in playground equipment and have released studies saying that high levels of lead are okay for children.

The EPA has a history of being vulnerable to the whims of Big Business. Most recently, pressure from the Bush administration and the fossil fuel lobby forced any mention of global warming out of the EPA’s 2002 air pollution report, even though the climate crisis had already been discussed in the report’s last five annual releases.

As far as public health and resources departments go, the EPA is certainly not alone in its vulnerability to corruption. Like the Board of Forestry (BOF) and United States Department of Agriculture (USDA), the EPA is staffed by the very people it is designed to regulate. In February of last year, it was discovered that Bush’s appointees to the EPA had sabotaged an effort to protect the public from mercury pollution caused by coal-burning power plants. Former industry lobbyists such as Jeffery Holmstead, Bush’s top air official to the EPA, admit that they blocked stronger environmental laws, favoring meaningless ones that came closer to the ineffective “Clear Skies” act. (Footnote 4)4

The public comment period for the new EPA ruling ended in December, and although any sane person would object to this rule, only about 50,000 were well-informed enough to raise their voices in opposition. We can only hope Congress will look at this new ruling and see it as the farce that it is.

To get involved, contact the Organic Consumer’s Association. (218) 226-4164. You can call your congress person and tell them you support a ban on ALL pesticide research on children and pregnant women. Dianne Feinstien (D-CA): 202-224-3841. Barbara Boxer (D-CA) 202-224-3553. Finally, you can call your regional EPA office and tell them that you demand a more stringent ruling that favors the public welfare over industry profits. (415)947-8021.


1. “Protections for Subjects in Human Research” http://www.epa.gov/fedrgstr/EPA-GENERAL/2005/September/Day-12/g18010.htm
2. Chemical Industry Archives, “Voluntary Chemical Safety Testing: How Self-Regulation Blocked Independent Science” http://www.chemicalindustryarchives.org/dirtysecrets/testing/1.asp
3. National Resources Defense Council, “Officials Blocked EPA from Protecting Public from Harmful Mercury Pollution from Power Plants” 2/4/05 http://www.nrdc.org/media/pressreleases/050204.asp