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Policy Recommendations

What we can do to prevent unnecessary exposure to toxic chemicals

“Prevention of learning and developmental disabilities is both an individual and a community responsibility,” says project participant Stephen Boese, MSW. However, current laws “simply do not work, and have done virtually nothing to assure Americans that our everyday products are safe for use.”

As individuals, we make choices in consumption and lifestyle that may reduce our own exposure to toxic chemicals. But individuals cannot avoid toxic chemicals entirely and should not have to bear the burden of finding safe products. Instead, we need to ensure chemicals are safe and tested prior to entering our consumer goods, homes, and bodies.

“A terrible responsibility”

Laura Abulafia

Laura Abulafia, MHS, a young woman engaged to be married, finds it disquieting to consider the effects of toxic chemical exposures on the family she and her future husband hope to have.

“With all that we know about these chemicals — like mercury, lead, and BPA — and with all the research out there on advanced technologies that would allow us to move away from using these chemicals in our industries and in our daily products, I’m deeply disturbed and feel very helpless that these known toxic chemicals are still being used, still left unregulated.

“Should my child be born with a serious disability or disorder, it would be a terrible responsibility wondering what I did wrong or what I could have done differently. I don’t want to live in fear that the food I eat and the products I use will impact my future children. And I shouldn’t have to. None of us should have to.”

PBDEs and breast milk: A Swedish biomonitoring success story

In 1998, as described in a 2003 commentary in the peer-reviewed journal Environmental Health Perspectives, analysis of archived breast milk samples in Sweden showed that PBDE levels in breast milk had been doubling every five years for the previous 25 years. Use of PBDEs was subsequently phased out in Sweden. Measurements have shown a steep decline in levels of PBDEs in breast milk following the phase-out.97 In the same time period, levels of PBDEs in North American breast milk have skyrocketed, exposing our tiniest and most vulnerable citizens to a known neurotoxin in the very first hours of their lives.98

Patching the chemical safety net: Ten policy steps to protect our health, potential, and future

A reformed Toxic Substances Control Act (TSCA) would serve as the backbone of a sound and comprehensive chemicals policy that protects public health and the environment, while restoring the luster of safety to U.S. goods in the world market. An effective reform of TSCA should:

1. Immediately Initiate Action on the Worst Chemicals

Persistent, bioaccumulative toxicants (PBTs) are uniquely hazardous. Any such chemical to which people could be exposed should be phased out of commerce. Exposure to other toxic chemicals, such as formaldehyde, that have already been extensively studied, should be reduced to the maximum extent feasible.

2. Require Basic Information for All Chemicals

Manufacturers should be required to provide basic information on the health hazards associated with their chemicals, how they are used, and the ways that the public or workers could be exposed.

3. Protect the Most Vulnerable

Chemicals should be assessed against a health standard that explicitly requires protection of the most vulnerable subpopulations. That population is likely to be children, but could also be workers, pregnant women, or another vulnerable population.

4. Use the Best Science and Methods

The National Academy of Sciences’ recommendations for reforming risk assessment at the Environmental Protection Agency (EPA) should be adopted. Regulators should expand development and use of information gleaned from “biomonitoring,” the science of detecting human chemical contamination, to inform and impel efforts to reduce these exposures.

5. Hold Industry Responsible for Demonstrating Chemical Safety

Unlike pharmaceuticals, chemicals are currently presumed safe until proven harmful. The burden of proving harm falls entirely on EPA. Instead, chemical manufacturers should be responsible for demonstrating the safety of their products.

6. Ensure Environmental Justice

Effective reform should contribute substantially to reducing the disproportionate burden of toxic chemical exposure placed on people of color, low-income people, and indigenous communities.

7. Enhance Government Coordination

EPA should work effectively with other agencies, such as FDA, that have jurisdiction over some chemical exposures. The ability of the states to enact tougher chemical policies should be maintained and state/federal cooperation on chemical safety encouraged.

8. Promote Safer Alternatives

There should be national support for basic and applied research into green chemistry and engineering, and policy should favor chemicals and products that are shown to be benign over those with potential health hazards.

9. Ensure the Right to Know

The public, workers, and the marketplace should have full access to information about the health and environmental hazards of chemicals and the way in which government safety decisions are made.

10. Require Labeling of Chemical Ingredients in Products

Many of the everyday products we use that may have been formulated with toxic chemicals are not required to have labels indicating the use of these ingredients, both active and inert. Some fabrics, for example, are treated with PFCs to prevent staining or with some forms of PBDEs in order to make them fire-resistant. Full disclosure of product ingredients will allow consumers, retailers and businesses to make informed decisions.

The U.S. population is exposed to neurotoxic and neurodevelopmentally toxic chemicals that increase the risk of learning and behavior problems — imposing significant economic and social costs to society. The incidence and costs of learning and developmental disabilities will keep rising unless we reform chemical policies to protect the health of current and future generations.