US EPA's "Voluntary Children's Chemical Evaluation Program is inadequate and likely to forestall progress on protecting kids from chemical threats to their health.

The US Environmental Protection Agency has announced the initial details of a new program designed to gather information about chemical threats to children's health. While the program may be based on the best of intentions, it appears likely to be more greenwashing than substance. Voluntary chemical testing programs involving the EPA and industry in the past have--without exception--provided very little information very slowly, yet been touted incessantly as responsible steps being taken by industry in the name of "responsible care." Their only benefit is to industry, as they provide excuses for why no additional action is required.

In the program, EPA is asking companies which manufacture and/or import 23 chemicals which have been found in human tissues and the environment in various monitoring programs to volunteer to sponsor their evaluation. According to the EPA: "As part of their sponsorship, companies would collect and/or develop health effects and exposure information on their chemical(s) and integrate that information in a risk assessment. A "Data Needs Assessment" would also be developed by the sponsor."

The impacts that will be examined under the first stage of assessment are a very limited set of traditional endpoints: acute toxicity, mutations, chromosomal aberrations and "repeated dose toxicity with reproductive and developmental toxicity screens." None of these address the concerns raised by Our Stolen Future of low level impacts on hormonal signalling. The reproductive and developmental toxicity screens referred to by EPA are extremely crude and inadequate.

The commitments made by companies are only to the first stage of testing, "Tier 1," which does not include prenatal developmental toxicity, immunotoxicity, reproductive/fertility toxicity, developmental neurotoxicity, neurotoxicity screening, or carcinogenesis.

Later stages in the program, "Tier 2" and "Tier 3", involve some of these more sophisticated assessments, but no commitments have been made to carry them out. In the past, similar voluntary programs have stalled somewhere early in Tier 1, never produced adequate results even at that stage, and never gotten to testing necessary to really assess threats to children's health. For information about these potential impacts of exposure to these few commonly used chemicals, we will continue to wait, while exposures continue.

The program has two other conspicuous flaws:

• First, it is testing only a small fraction of the tens of thousands of chemicals in use in modern commerce today... and the chemicals being tested are those that industry has volunteered to test, not those identified by independent toxicologists and epidemiologists as being of highest priority.
• Second, it depends upon industry-acquired information that is conveyed voluntarily to the EPA. All too often, industry-based science underestimates the risks, and industry lawyers withhold information [visit the Chemical Industry Archives for examples].

EPA should use a process that is independent of vested interests to identify priority chemicals for testing, and should create a funding mechanism--using payments from manufacturing companies that insulates the science from industry pressure--to fully fund the costs of evaluation.

These voluntary programs in the past have turned out to be shams and tactics for delay. There is no reason to think this one is any different.