Richard Denison, Ph.D., is a Senior Scientist.
A long-awaited and full-throated endorsement of comprehensive reform of the Toxic Substances Control Act (TSCA) from the venerable American Academy of Pediatricians (AAP) was published online yesterday in the journal Pediatrics.
Right down the line, the AAP’s 8-page policy statement calling for a wholesale overhaul of TSCA mirrors the recommendations of health and environmental advocates, academic researchers and just about anyone else who has paid attention to the mounting body of evidence documenting the linkages between rising chemical exposures and adverse effects on the health of our population, especially the most vulnerable among us: the developing fetus, infants and young children.
The AAP’s recommendations also closely track key provisions in TSCA reform bills introduced last year in both Houses of Congress as well as the Safe Chemicals Act of 2011 just re-introduced in the U.S. Senate this month.
This latest statement from the Academy adds it to the list of other major medical and health associations that have previously called on Congress to revamp TSCA, including the American Medical Association, the American Public Health Association and the American Nurses Association.
Given this growing chorus, it is perhaps not surprising that the American Chemistry Council (ACC) would seek to worm its way in to claim that it, too, loves kids and supports TSCA reform.
But dig a bit deeper, and what is most striking is that ACC stridently opposes essentially every element of TSCA reform called for by the American Academy of Pediatrics.
The Safer Chemicals Healthy Families coalition, of which EDF is a founding member, issued a statement yesterday on the AAP announcement. It identifies five blatant contradictions between the AAP recommendations and ACC’s actual positions articulated in the TSCA reform debate:
- The Academy explicitly says that old and new chemicals should have to meet the same safety requirements for evidence. The ACC has virulently opposed the provisions in both House and Senate legislation last year that did just that.
- The Academy says that chemicals should be evaluated for both their aggregate and cumulative effects. (Aggregate is the combined exposure to one chemical from several sources. Cumulative is the combined exposure to different chemicals that have similar effects.) The ACC ridiculed both concepts in House testimony last July.
- The Academy endorses the safety standard in the new Safe Chemicals Act (also present in last year's legislation) pointing to its success in the area of pesticides. The ACC has strenuously opposed the standard — again, with a tone that could be described as ridicule — while refusing to propose a different one.
- The Academy endorses minimum information and testing requirements for chemicals when they are proposed to be marketed, including, but not limited to, reproductive and developmental toxicity, neurotoxicity, and endocrine disruption. The ACC has opposed minimum information requirements for chemicals.
- Perhaps most importantly, the Academy's first recommendation is that while the EPA should base its decisions about chemicals on evidence, those decisions should be based on "reasonable levels of concern and not depend on demonstrated negative health effects after release." This statement is a helpful reminder to policy makers to take a public health approach, rather than a criminal law approach to decisions about chemicals. At the point at which a chemical can be absolutely proven to have hurt people, it is too late.
Sure, everybody says they love kids. W.C. Fields said he liked kids too.
But shouldn’t Congress be listening more to those professionals whose job it is to actually protect children than to those who are intent on protecting little more than their own narrow and short-sighted self-interest?