Re-Evaluate
Environmental Regulations
to Ensure Protection of
Children’s Health
for U.S. Environmental
Protection Agency, Office
of Children’s Health
Protection
From
the Preamble of the Final
Report:
The
Children’s Health
Protection Advisory Committee
(CHPAC) was formed to
advise, consult with,
and make recommendations
to the U.S. Environmental
Protection Agency (EPA)
on issues associated with
the development of regulations
to address the prevention
of adverse health effects
to children.
One of the
CHPAC’s primary mission’s
is to identify five existing
EPA regulations, which
if re-evaluated, could
lead to better protection
for children. The CHPAC
established a highly iterative
process, which involved
the development of guiding
criteria, review of potential
environmental health risks
to children, and an assessment
of the status of regulation,
enforcement, and implementation.
The CHPAC, with its broad
representation of industry,
environmental, health,
and children’s organizations,
arrived at consensus agreements
through its deliberations.
This reflected the CHPAC
members’ common commitment
to find better ways to
incorporate children’s
health concerns into environmental
regulatory decision making.
One key
tool for assisting the
CHPAC with its deliberations
was the development of
seven screening criteria
to select rules for re-evaluation
that would lead to strengthening
children’s health
protection (See Attachment
A). The CHPAC approached
the assignment to identify
five existing regulations
from a holistic, health-based
strategy. It first considered
specific toxic substances
or exposures that may
pose a greater health
risk to children, and
then determined which
regulatory provisions
were applicable. For instance,
if the CHPAC determined
that new evidence was
available on a substance’s
risks to children, then
this information should
be incorporated into all
regulations of that chemical.
In re-evaluating regulations,
children’s differential
and cumulative routes
of exposure should be
considered. Thus, the
CHPAC’s recommendations
are listed as issues of
concern, with the specific
regulations identified
under each heading.
The five
issues selected by the
CHPAC are:
• Mercury;
• (Farm) Worker
Protection Standard;
• Triazine Pesticides;
• Organophosphates
and Carbamates; and
• Air Quality and
Asthma.
During the
CHPAC’s deliberation
process, several critical
issues were identified
but not selected because
they were beyond the immediate
task of identifying five
existing regulations for
expedited review or because
of regulatory timing conflicts.
These issues represent
important opportunities
for EPA to tackle serious
potential health risks
to children, but broader
agency policies, authorities,
or structure may need
to be reconsidered. Therefore,
the CHPAC also provided
broad recommendations
that merit the attention
of EPA. The CHPAC hopes
that their broad recommendations
for process improvements
will receive expeditious
action and make meaningful
long term enhancements
to EPA’s efforts
to protect children’s
health. The CHPAC expects
EPA to report back on
their recommendations
to re-propose or not re-propose
the selected regulations
by December 1998, and
hopes to continue to advise
EPA throughout its regulatory
re-evaluation.
