Fact #3: The fetus, infants, and children are especially vulnerable to toxic substances
Infants and children are not little adults, and they are often more vulnerable to the adverse effects of drugs, chemicals, radiation or disease. In spite of this fact, only one law, that covering pesticides, requires regulators to base safety judgments explicitly on risks faced by the fetus, infant and child, and even this statute has not been rigorously implemented.
For most toxic substances in commerce and consumer products, there are few if any health studies at all. Those that are done are typically done on adult (sexually mature) test animals.
The fetus, infants and children are more vulnerable to toxic substances:
Nitrate - Prolonged exposure to tap water with 20 ppm nitrate can kill an infant, but will have no observable effect on an adult.
Mercury - Exposure in the womb at 100 parts per billion will significantly increase the likelihood of learning deficits in childhood, while the same dose during adulthood has no measurable effect.
Radiation - Children exposed to radiation have a much higher incidence of cancer than adults exposed to the same dose.
PCBs - Levels of fetal PCB exposure that cause learning deficits that persist through adolescence, have no measurable effects on adults.
Ritalin - This commonly prescribed drug acts as a depressant and calming agent in children, but has the opposite effect in adults.
Honey - Infants under one year of age can contract a potentially fatal paralytic form of botulism from eating honey. In older children and adults the digestive system is more acidic and it destroys the botulism toxins present in the honey.
Lead - Doses at age 2 that cause IQ deficits throughout childhood produce no effect in adults.
Researchers at a 1997 EPA sponsored national conference on children's environmental health summarize children's vulnerability in the context of chemical exposures (Landrigan et al 1998):
"Many organ systems in young children - the nervous system in particular, but also the lungs, the immune system, and the reproductive organs - undergo extensive growth and development throughout pregnancy and in the first months and years of extra-uterine life. During this period, structures are developed and vital connections established. These systems are not well adapted to repair any damage that may be caused by environmental toxicants. Thus, if cells in the developing brain, immune system, or reproductive organs are destroyed by neurotoxicants, or if development is diverted by endocrine disruptors, there is high risk that the resulting dysfunction will be permanent and irreversible. Depending on the organ damaged, the consequences can include loss of intelligence, immune dysfunction, or reproductive impairment."
Two important factors make the young more vulnerable.
1. The developing human body, particularly the fetus, has critical windows of vulnerability
Many studies have shown that the peak incidence of birth defects coincides with the timing of key developmental events. This means that maternal exposures to toxic substances on a particular day of pregnancy might cause devastating effects to a baby, while exposures on the very next day would cause no discernible effects whatsoever. For example, implantation of the egg occurs on gestational day 6 to 7; organs begin forming on days 21 through 56; the neural plate forms between days 18 and 20; arm buds appear on days 29 to 30, and leg buds follow shortly after on days 31 to 32; testes differentiation occurs on day 43, and the palate closes between days 56 and 58.
The brain is a particularly sensitive target for early-life exposures. The blood brain barrier, which protects the developing brain from some chemical exposures, is not fully developed at birth. Chemical substances have been shown to be three to ten times as toxic to newborns as adults, or in some cases to damage the newborn brain and not the adult brain, in part due to differences in the stages of development of the blood-brain barrier (Klassen 1996).
The human brain develops in overlapping phases, each presenting unique opportunities for chemical-induced damage, beginning in the womb within days of conception, and continuing through childhood. The right chemical at the right time has the potential to disrupt any of these processes.
*Making brain cells (neurulation and neurogensis)
*Moving the cells to their proper location (cell migration)
*Growing axons and dendrites to link nerve cells (neuronal differentiation and pathfinding)
*Developing synapses or points of communication with other cells (synaptogenesis)
*Refining the synapses (naturation and pruning), and, finally,
*Forming the supportive tissue that surrounds nerve cells and makes for efficient communication among them (gliagenesis or myelination).
Sensitivities continue through childhood. An increasing number of studies are showing effects to the reproductive system and the brain following early-life exposures to an array of chemicals. This is well-proven for childhood exposures to lead, and is shown in laboratory animals for, among other things, high-volume chemicals like dibutyl phthalate and bis(2-ethylhexyl) phthalate.
2. Pound for pound, children get higher doses of chemicals than adults
For example, one part per billion of benzene in drinking water, air, or food translates into a greater exposure for a small child than an adult, because:
*Children in the first six months of life drink seven times as much water per pound as does the average American adult.
*Children one through five years of age eat three to four times more food per pound than the average adult.
*Resting infants breathe twice as much air, pound for pound, as resting adults (Landrigan et al 1998).
*Children from birth to two years of age have more than twice the body surface area of an adult - an important factor for the many chemicals that can absorb through skin (EPA 1997).
*Just doing what children normally do can increase doses of chemicals. For instance, children put their hands in their mouths more often than adults, and play closer to the floor where some chemicals are more likely to be concentrated (Landrigan et al 1998).
References
Landrigan PJ, JE Carlson, CF Bearer, JS Cranmer, RD Bullard, RA Etzel, J Groopken, JA McLachlan, FP Perera, JR Reigart, L Robison, L Schell, WA Suk. Children's health and the environment: A new agenda for prevention research. Environmental Health Perspectives 106, Supplement 3, June 1998.
U.S. Environmental Protection Agency (EPA). 1997. Exposure Factors Handbook. Volume 1 - General Factors. EPA/600/P-95/002Fa. August 1997.
Klassen, Curtis D. Casarett & Doull's Toxicology. The Basic Science of Poisons. Fifth Edition. The McGraw-Hill Companies, Inc. 1996.
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Thursday, October 9, 2008
Wednesday, October 8, 2008
Babies Absorb Phthalates From Baby Products
(Reuters Health) - A new study suggests that baby lotion, baby powder, and baby shampoo may be exposing babies to potentially harmful chemicals called phthalates.
"At this time, we do not know what the potential long-term health effects might be, but there is a large body of animal studies to suggest developmental and reproductive toxicity (from phthalates) and a few human studies with changes in health outcomes as well," Dr. Sheela Sathyanarayana told Reuters Health.
Phthalates are used to make plastics flexible and stabilize fragrances, and are found in a plethora of consumer products including toys, personal care products and medical equipment.
As reported online today in the journal Pediatrics, Sathyanarayana, from the university of Washington, Seattle, and colleagues measured the levels of nine different phthalate breakdown products in urine from diapers of 163 infants aged 2 to 28 months.
All of the urine samples contained at least one phthalate at measurable levels, they report, and 81 percent of the samples had measurable amounts of seven or more phthalates.
"We found that reported use of baby lotion, baby shampoo, and baby powder was associated with increased concentrations of monethyl phthalate (MEP), monomethyl phthalate (MMP), and monoisobutyl phthalate (MIBP) in infant urine," Sathyanarayana said.This association was strongest in young infants less than 8 months old, "who may be more vulnerable to developmental and reproductive toxicity of phthalates," the investigators note in their report.
At present, U.S. manufacturers are not required to list phthalate contents on products' package labels, making it hard for parents to make informed decisions, the investigators point out.
"If parents want to decrease exposures for their children, they can try to use lotions, shampoo, and baby powder sparingly unless otherwise indicated for a medical reason," Sathyanarayana suggested.
SOURCE: Pediatrics, February 2008.
"At this time, we do not know what the potential long-term health effects might be, but there is a large body of animal studies to suggest developmental and reproductive toxicity (from phthalates) and a few human studies with changes in health outcomes as well," Dr. Sheela Sathyanarayana told Reuters Health.
Phthalates are used to make plastics flexible and stabilize fragrances, and are found in a plethora of consumer products including toys, personal care products and medical equipment.
As reported online today in the journal Pediatrics, Sathyanarayana, from the university of Washington, Seattle, and colleagues measured the levels of nine different phthalate breakdown products in urine from diapers of 163 infants aged 2 to 28 months.
All of the urine samples contained at least one phthalate at measurable levels, they report, and 81 percent of the samples had measurable amounts of seven or more phthalates.
"We found that reported use of baby lotion, baby shampoo, and baby powder was associated with increased concentrations of monethyl phthalate (MEP), monomethyl phthalate (MMP), and monoisobutyl phthalate (MIBP) in infant urine," Sathyanarayana said.This association was strongest in young infants less than 8 months old, "who may be more vulnerable to developmental and reproductive toxicity of phthalates," the investigators note in their report.
At present, U.S. manufacturers are not required to list phthalate contents on products' package labels, making it hard for parents to make informed decisions, the investigators point out.
"If parents want to decrease exposures for their children, they can try to use lotions, shampoo, and baby powder sparingly unless otherwise indicated for a medical reason," Sathyanarayana suggested.
SOURCE: Pediatrics, February 2008.
Tuesday, October 7, 2008
It Takes Action To Achieve Your Goals
The odds that you’ll succeed in achieving any of your goals without taking action are about the same as winning the lottery without buying a ticket!
For those times when you feel trapped, stressed, or in a prison of your own making, take massive, intentional, purposeful goal directed action. It’s the ultimate silver bullet.
In real estate, it’s location, location, location. In goal-setting , its action, action, action.
You can’t just stick out your thumb and hitchhike your way to success. You’ve got to roll up your sleeves and do the work that needs to be done.
Whether your goal is to be or not to be is largely dependent upon your actions.
The cure for the ills of procrastination is a heavy prescription of action, until the day arrives when your goals and their achievement are one in the same-until you cannot tell them apart.
Keep this in mind, a good plan will almost always get you in the door, but it is action that seals the deal.
For those times when you feel trapped, stressed, or in a prison of your own making, take massive, intentional, purposeful goal directed action. It’s the ultimate silver bullet.
In real estate, it’s location, location, location. In goal-setting , its action, action, action.
You can’t just stick out your thumb and hitchhike your way to success. You’ve got to roll up your sleeves and do the work that needs to be done.
Whether your goal is to be or not to be is largely dependent upon your actions.
The cure for the ills of procrastination is a heavy prescription of action, until the day arrives when your goals and their achievement are one in the same-until you cannot tell them apart.
Keep this in mind, a good plan will almost always get you in the door, but it is action that seals the deal.
Monday, October 6, 2008
Fact #2
Fact #2: People vary enormously in their reaction to toxic substances
People are incredibly different in their reactions to chemicals, allergens, drugs, diseases and a host of external stimuli. That's why the government applies safety factors to the results of animal studies when they set safe exposure limits for pollutants or contaminants in food and water. Often, however, these safety factors are not enough to protect large numbers of sensitive people.
Many factors determine how a drug, allergen, or toxic substance will affect a person - genetics, metabolism, age, sex, size, disease, diet, and environment. (Gibson and Skett, 1994). The result is vast variability in the human response to chemicals, viruses, drugs and a host of substances (up to 100,000 fold differences), most of which is influenced by factors that individuals cannot control.
Allergies
There are enormous differences between sensitive and 'immune' populations in their reaction to common allergens. Some common food allergies powerfully illustrate the point. Peanut butter can easily kill people who are allergic to it, while those who are not can eat as much as they can stand, with no effects at all. At least three people have died from peanut allergy using a knife that had been 'wiped' after making a peanut butter sandwich. About 6 tenths of one percent of the U.S. population (2 million people) is allergic to peanuts. (Sampson 2001) The same phenomenon occurs with non-lethal allergies. A recent EPA sponsored review found that sensitive individuals are up to 450 times more sensitive than the median (average) person to common allergens like ragweed and wheat flour. (Hattis 2001).
Genetic Differences
The recently completed map of the human genome has revealed the tremendous genetic variability in the human population. Scientists have identified an estimated 1.4 million specific differences, or polymorphisms, in the human genetic code. Every polymorphism on a human gene is a DNA sequence that differs from one person to the next. Each of these 1.4 million polymorphisms represents a chance for a person to be at risk for a particular disease or uniquely susceptible to the harmful effects of a particular chemical (Stoneking 2001). Put another way, there are now truly 1 million ways that a person could be more or less sensitive to toxic chemicals than his or her neighbor.
Metabolism
Differences in metabolism dramatically influence the toxicity or effectiveness of chemicals and drugs. Metabolism is a function of genetically determined factors including race, age, sex,, and inherent variability (polymorphisms) as well as external factors like diet, disease-state, and exposure to chemical pollutants and heavy metals. One well-characterized genetic variable is the difference in critical metabolic enzyme levels. From 3 to 10 percent of Caucasians "do not have" or "have either low or no activity" of the enzyme (CYP2D6) that metabolizes codeine and the prescribed tricyclic antidepressants (Richelson 1997). Poor functioning, but normally occurring enzyme levels can also make individuals far more vulnerable to toxic chemical exposure. About 30 percent of the population carries a poor version of the enzyme paraoxonase which makes them 11 times more vulnerable to certain neurotoxic insecticides than people with fully functioning paraoxonase (Schettler 2000).
Natural Immunity
Individuals with a 'natural' immunity to typhoid fever are 10,000 times more resistant to the disease than the average person. These people show no symptoms when exposed to 1 billion viable salmonella typhosa organisms, whereas some people get the disease after exposure to just 10,000. (Hornwick 1970) Similarly, people with a 'natural' immunity to rotavirus (a virus causing diarrheal disease in infants and young children) are 100,000 times more resistant than the weakest person (Ward, et al. 1986). These are just two examples of the obvious fact that peoples' immune systems are enormously different, often in ways that are little understood by scientists.
Chemical Absorption
Absorption in the gut may vary by orders of magnitude. While some people who eat mercury contaminated fish absorb 13% of the mercury from their stomach into their blood, others only absorb only 1% (Stern 1997). This means that if two pregnant women eat the same amount of mercury in a fish, one could deliver ten times more mercury to the brain of her developing child.
References
Gibson, G. and P. Skett, 1994, "Chapter 4: Factors affecting drug metabolism: internal factors," in Introduction to drug metabolism, London: Blackie Academic & Professional.
Hattis, D., A. Russ, R. Goble, et al., 2001, Human interindividual variability in susceptibility to airborne particles, submitted to Risk Analysis.
Hornwick, R., S. Greisman, T. Woodward, et al., 1970, Typhoid fever: pathogenesis and immunologic control, N. Eng. J. Med., 283, 686-691.
Richelson, E., 1997, Pharmacokinetic drug interactions of new antidepressants: a review of the effects on the metabolism of other drugs, Mayo Clin. Proc., 72, 835-847.
Sampson, H., 2001, Personal correspondence via email.
Schettler T, J Stein, F Reich, M Valenti. 2000. In Harm's Way: Toxic Threats to Child Development. Greater Boston Physicians for Social Responsibility. May 2000.
Stern, Alan H. 1997. Estimation of the interindividual variability in the one-compartment pharmacokinetic model for methylmercury: Implications for the derivation of a Reference Dose. Regulatory Toxicology and Pharmacology. 25. 277-288.
Stoneking M., 2001. Single nucleotide polymorphisms: from the evolutionary past . . . Nature. 409. 15 February 2001.
Ward, R., D. Bernstein, E. Young, et al., 1986, Human rotavirus studies in volunteers: determination of infectious dose and serological response to infection, J. Infect. Disease, 154, 871-880.
People are incredibly different in their reactions to chemicals, allergens, drugs, diseases and a host of external stimuli. That's why the government applies safety factors to the results of animal studies when they set safe exposure limits for pollutants or contaminants in food and water. Often, however, these safety factors are not enough to protect large numbers of sensitive people.
Many factors determine how a drug, allergen, or toxic substance will affect a person - genetics, metabolism, age, sex, size, disease, diet, and environment. (Gibson and Skett, 1994). The result is vast variability in the human response to chemicals, viruses, drugs and a host of substances (up to 100,000 fold differences), most of which is influenced by factors that individuals cannot control.
Allergies
There are enormous differences between sensitive and 'immune' populations in their reaction to common allergens. Some common food allergies powerfully illustrate the point. Peanut butter can easily kill people who are allergic to it, while those who are not can eat as much as they can stand, with no effects at all. At least three people have died from peanut allergy using a knife that had been 'wiped' after making a peanut butter sandwich. About 6 tenths of one percent of the U.S. population (2 million people) is allergic to peanuts. (Sampson 2001) The same phenomenon occurs with non-lethal allergies. A recent EPA sponsored review found that sensitive individuals are up to 450 times more sensitive than the median (average) person to common allergens like ragweed and wheat flour. (Hattis 2001).
Genetic Differences
The recently completed map of the human genome has revealed the tremendous genetic variability in the human population. Scientists have identified an estimated 1.4 million specific differences, or polymorphisms, in the human genetic code. Every polymorphism on a human gene is a DNA sequence that differs from one person to the next. Each of these 1.4 million polymorphisms represents a chance for a person to be at risk for a particular disease or uniquely susceptible to the harmful effects of a particular chemical (Stoneking 2001). Put another way, there are now truly 1 million ways that a person could be more or less sensitive to toxic chemicals than his or her neighbor.
Metabolism
Differences in metabolism dramatically influence the toxicity or effectiveness of chemicals and drugs. Metabolism is a function of genetically determined factors including race, age, sex,, and inherent variability (polymorphisms) as well as external factors like diet, disease-state, and exposure to chemical pollutants and heavy metals. One well-characterized genetic variable is the difference in critical metabolic enzyme levels. From 3 to 10 percent of Caucasians "do not have" or "have either low or no activity" of the enzyme (CYP2D6) that metabolizes codeine and the prescribed tricyclic antidepressants (Richelson 1997). Poor functioning, but normally occurring enzyme levels can also make individuals far more vulnerable to toxic chemical exposure. About 30 percent of the population carries a poor version of the enzyme paraoxonase which makes them 11 times more vulnerable to certain neurotoxic insecticides than people with fully functioning paraoxonase (Schettler 2000).
Natural Immunity
Individuals with a 'natural' immunity to typhoid fever are 10,000 times more resistant to the disease than the average person. These people show no symptoms when exposed to 1 billion viable salmonella typhosa organisms, whereas some people get the disease after exposure to just 10,000. (Hornwick 1970) Similarly, people with a 'natural' immunity to rotavirus (a virus causing diarrheal disease in infants and young children) are 100,000 times more resistant than the weakest person (Ward, et al. 1986). These are just two examples of the obvious fact that peoples' immune systems are enormously different, often in ways that are little understood by scientists.
Chemical Absorption
Absorption in the gut may vary by orders of magnitude. While some people who eat mercury contaminated fish absorb 13% of the mercury from their stomach into their blood, others only absorb only 1% (Stern 1997). This means that if two pregnant women eat the same amount of mercury in a fish, one could deliver ten times more mercury to the brain of her developing child.
References
Gibson, G. and P. Skett, 1994, "Chapter 4: Factors affecting drug metabolism: internal factors," in Introduction to drug metabolism, London: Blackie Academic & Professional.
Hattis, D., A. Russ, R. Goble, et al., 2001, Human interindividual variability in susceptibility to airborne particles, submitted to Risk Analysis.
Hornwick, R., S. Greisman, T. Woodward, et al., 1970, Typhoid fever: pathogenesis and immunologic control, N. Eng. J. Med., 283, 686-691.
Richelson, E., 1997, Pharmacokinetic drug interactions of new antidepressants: a review of the effects on the metabolism of other drugs, Mayo Clin. Proc., 72, 835-847.
Sampson, H., 2001, Personal correspondence via email.
Schettler T, J Stein, F Reich, M Valenti. 2000. In Harm's Way: Toxic Threats to Child Development. Greater Boston Physicians for Social Responsibility. May 2000.
Stern, Alan H. 1997. Estimation of the interindividual variability in the one-compartment pharmacokinetic model for methylmercury: Implications for the derivation of a Reference Dose. Regulatory Toxicology and Pharmacology. 25. 277-288.
Stoneking M., 2001. Single nucleotide polymorphisms: from the evolutionary past . . . Nature. 409. 15 February 2001.
Ward, R., D. Bernstein, E. Young, et al., 1986, Human rotavirus studies in volunteers: determination of infectious dose and serological response to infection, J. Infect. Disease, 154, 871-880.
Sunday, October 5, 2008
Health Tests Are Not Required By Law
Fact #1: No health tests are required by law to put a chemical on the market
As amazing as it may seem, there are no mandatory pre-market health testing or approval requirements under any federal law for chemicals in cosmetics, toys, clothing, carpets, or construction materials, to name just a few obvious sources of chemical exposure in everyday life.
The EPA does require some tests for a handful of new compounds (as opposed to heavily used older compounds) via the pre-manufacture notice (PMN) program. These tests provide little protection for the public, however, because they apply only to chemicals that are new and little used, and because studies for critical human health effects like cancer, birth defects, and nervous system toxicity are rarely if ever required.
This explains in large part why products like hair spray, hair dye, pacifiers, stain repellants, glues, construction materials, and plastic wraps, just to name a few, are put into commerce for decades before their dangers are discovered and the products are removed or reformulated.
Here is how the FDA describes testing requirements for chemicals in cosmetics:
FDA is only able to regulate cosmetics after products are released to the marketplace. Neither cosmetic products nor cosmetic ingredients are reviewed or approved by FDA before they are sold to the public. (FDA 1995)
Here is how EPA describes its authority to require health testing under the Toxic Substances Control Act. In general, EPA can require safety testing of chemicals only if the Agency can prove that the chemical potentially poses a risk, which it can almost never do because the law essentially prohibits the agency from mandating health studies by chemical manufacturers for every individual test it seeks:
EPA must make the following statutory "findings" in order to require the chemical industry to test chemicals they manufacture, import and/or process:
* Hazard or "A" Finding - EPA must determine that existing data show that the subject chemical "may present an unreasonable risk of injury to health or the environment" and that the probability of exposure to the subject chemical substance is more than just theoretical; and/or
* Exposure or "B" Finding - EPA must show that the chemical is produced or imported in substantial quantities, and either enters the environment in substantial quantities or there is substantial or significant human exposure; and
- EPA must show that existing data are inadequate for risk assessment; and
- EPA must show that testing is needed to develop the data necessary to conduct the needed risk assessment. (EPA 2001)
How did this happen?
The chemical industry wanted it this way.
Since the 1950's the chemical industry has effectively blocked efforts to require health studies for the compounds it produces. Comprehensive testing for the health effects of chemicals is not required under the Occupational Safety and Health Act, the Toxic Substances Control Act, nor the cosmetics provisions of the Food Drug and Cosmetics Act. (Testing is required for chemicals directly added to food).
But what about industry's voluntary testing program?
It's a total bust.
In 1998, the EPA and the chemical industry launched their much-ballyhooed voluntary testing program for high production volume chemicals. To date, the program has been little more than a PR exercise. As of February 2001, the EPA has received no new tests - zero - as a result of the HPV program. Indeed, only 17 plans for tests have been submitted so far, which cover about 10% of the chemicals that need to be tested. And the tests themselves are only screening tests, preliminary indicators of a toxic effect that will not support a regulatory action to restrict the use of a chemical.
The HPV voluntary testing program is not a victory for the public or a concession by industry. It is the end result of a decades-long coordinated strategy to avoid comprehensive testing requirements that would surely lead to restrictions on major products.
Voluntary testing means no testing
In 1998, EPA reported that 43% of 2,800 chemicals produced in volumes of 1,000,000 pounds per year or more, have no basic toxicity data, or screening level data, at all. Fifty percent have incomplete screening data, and only 7% of these so-called high production volume (HPV) chemicals have a complete set of screening level toxicity data. Screening level data, even if they indicate a problem, are not sufficient to restrict the use of a compound.
On October 9, 1998 EPA's administrator Carol Browner sent letters to the CEO's of more than 900 chemical companies that manufacture HPV chemicals, inviting them to participate in EPA's voluntary testing initiative, the "HPV Challenge Program." As of February, 2001, 28 months after these invitations were mailed, not a single test has been submitted and just 17 testing work plans have been submitted to EPA. About half of the companies have not responded, and presumably will not respond to the invitation, while 469 companies have indicated some level of commitment. Of the 2,863 chemicals initially identified, 25% (708 chemicals) remain entirely without a commitment for testing from the manufacturers.
The program deadline for all tests to be completed recently slid several years - EPA is now asking for all new test results to be submitted by 2005, but if past is prologue this deadline is not likely to be met.
Companies that fail to participate in the voluntary initiative may be subjected to formal testing requirements under legally binding test rules. In December 2000 EPA issued the first of these test rules, covering 37 of the 708 chemicals for which there is no voluntary testing commitment. If EPA continues this rulemaking pace each year, test rules for all 708 chemicals will be in place in the year 2022.
References
U.S. Food and Drug Administration (FDA). 1995. FDA authority over cosmetics. Center for Food Safety and Applied Nutrition, Office of Cosmetics Fact Sheet, February 3, 1995. http://vm.cfsan.fda.gov/~dms/cos-206.html.
U.S. Environmental Protection Agency (EPA). 2001. TSCA Chemical Testing Policy. Office of Pollution Prevention and Toxics. http://www.epa.gov/opptintr/chemtest/sct4main.htm
As amazing as it may seem, there are no mandatory pre-market health testing or approval requirements under any federal law for chemicals in cosmetics, toys, clothing, carpets, or construction materials, to name just a few obvious sources of chemical exposure in everyday life.
The EPA does require some tests for a handful of new compounds (as opposed to heavily used older compounds) via the pre-manufacture notice (PMN) program. These tests provide little protection for the public, however, because they apply only to chemicals that are new and little used, and because studies for critical human health effects like cancer, birth defects, and nervous system toxicity are rarely if ever required.
This explains in large part why products like hair spray, hair dye, pacifiers, stain repellants, glues, construction materials, and plastic wraps, just to name a few, are put into commerce for decades before their dangers are discovered and the products are removed or reformulated.
Here is how the FDA describes testing requirements for chemicals in cosmetics:
FDA is only able to regulate cosmetics after products are released to the marketplace. Neither cosmetic products nor cosmetic ingredients are reviewed or approved by FDA before they are sold to the public. (FDA 1995)
Here is how EPA describes its authority to require health testing under the Toxic Substances Control Act. In general, EPA can require safety testing of chemicals only if the Agency can prove that the chemical potentially poses a risk, which it can almost never do because the law essentially prohibits the agency from mandating health studies by chemical manufacturers for every individual test it seeks:
EPA must make the following statutory "findings" in order to require the chemical industry to test chemicals they manufacture, import and/or process:
* Hazard or "A" Finding - EPA must determine that existing data show that the subject chemical "may present an unreasonable risk of injury to health or the environment" and that the probability of exposure to the subject chemical substance is more than just theoretical; and/or
* Exposure or "B" Finding - EPA must show that the chemical is produced or imported in substantial quantities, and either enters the environment in substantial quantities or there is substantial or significant human exposure; and
- EPA must show that existing data are inadequate for risk assessment; and
- EPA must show that testing is needed to develop the data necessary to conduct the needed risk assessment. (EPA 2001)
How did this happen?
The chemical industry wanted it this way.
Since the 1950's the chemical industry has effectively blocked efforts to require health studies for the compounds it produces. Comprehensive testing for the health effects of chemicals is not required under the Occupational Safety and Health Act, the Toxic Substances Control Act, nor the cosmetics provisions of the Food Drug and Cosmetics Act. (Testing is required for chemicals directly added to food).
But what about industry's voluntary testing program?
It's a total bust.
In 1998, the EPA and the chemical industry launched their much-ballyhooed voluntary testing program for high production volume chemicals. To date, the program has been little more than a PR exercise. As of February 2001, the EPA has received no new tests - zero - as a result of the HPV program. Indeed, only 17 plans for tests have been submitted so far, which cover about 10% of the chemicals that need to be tested. And the tests themselves are only screening tests, preliminary indicators of a toxic effect that will not support a regulatory action to restrict the use of a chemical.
The HPV voluntary testing program is not a victory for the public or a concession by industry. It is the end result of a decades-long coordinated strategy to avoid comprehensive testing requirements that would surely lead to restrictions on major products.
Voluntary testing means no testing
In 1998, EPA reported that 43% of 2,800 chemicals produced in volumes of 1,000,000 pounds per year or more, have no basic toxicity data, or screening level data, at all. Fifty percent have incomplete screening data, and only 7% of these so-called high production volume (HPV) chemicals have a complete set of screening level toxicity data. Screening level data, even if they indicate a problem, are not sufficient to restrict the use of a compound.
On October 9, 1998 EPA's administrator Carol Browner sent letters to the CEO's of more than 900 chemical companies that manufacture HPV chemicals, inviting them to participate in EPA's voluntary testing initiative, the "HPV Challenge Program." As of February, 2001, 28 months after these invitations were mailed, not a single test has been submitted and just 17 testing work plans have been submitted to EPA. About half of the companies have not responded, and presumably will not respond to the invitation, while 469 companies have indicated some level of commitment. Of the 2,863 chemicals initially identified, 25% (708 chemicals) remain entirely without a commitment for testing from the manufacturers.
The program deadline for all tests to be completed recently slid several years - EPA is now asking for all new test results to be submitted by 2005, but if past is prologue this deadline is not likely to be met.
Companies that fail to participate in the voluntary initiative may be subjected to formal testing requirements under legally binding test rules. In December 2000 EPA issued the first of these test rules, covering 37 of the 708 chemicals for which there is no voluntary testing commitment. If EPA continues this rulemaking pace each year, test rules for all 708 chemicals will be in place in the year 2022.
References
U.S. Food and Drug Administration (FDA). 1995. FDA authority over cosmetics. Center for Food Safety and Applied Nutrition, Office of Cosmetics Fact Sheet, February 3, 1995. http://vm.cfsan.fda.gov/~dms/cos-206.html.
U.S. Environmental Protection Agency (EPA). 2001. TSCA Chemical Testing Policy. Office of Pollution Prevention and Toxics. http://www.epa.gov/opptintr/chemtest/sct4main.htm
Fact Versus Fiction
If you've followed the debates about chemical contaminants in the environment, you've probably already heard at least one of these claims before:
"These chemicals meet EPA standards."
"You'd have to drink a swimming pool of this stuff before it would affect you."
"There's no evidence that this compound harms humans."
The chemical industry and their hired public relations representatives trot out these and similar claims whenever the safety of one of their compounds is called into question.
On their surface, many of these statements appear reasonable. But once you scratch the surface, they prove to be little more than carefully constructed fictions and half-truths that obscure the real facts: that EPA requires little or no testing of compounds before they are released to the environment; that cancer rates are up, especially for the young; and that certain, particularly young children, are extremely sensitive to certain compounds.
Before you spread the industry's stories about chemical exposure, make sure you have the facts.
For Free Information In Your Decision making, Visit Here.
"These chemicals meet EPA standards."
"You'd have to drink a swimming pool of this stuff before it would affect you."
"There's no evidence that this compound harms humans."
The chemical industry and their hired public relations representatives trot out these and similar claims whenever the safety of one of their compounds is called into question.
On their surface, many of these statements appear reasonable. But once you scratch the surface, they prove to be little more than carefully constructed fictions and half-truths that obscure the real facts: that EPA requires little or no testing of compounds before they are released to the environment; that cancer rates are up, especially for the young; and that certain, particularly young children, are extremely sensitive to certain compounds.
Before you spread the industry's stories about chemical exposure, make sure you have the facts.
For Free Information In Your Decision making, Visit Here.
Friday, October 3, 2008
I need a debate redo.... LOL


What a debate.... I have now seen with my own eyes that Sarah can actually speak and answer questions. Unlike the other day when she was asked what magazines she reads and she could not even mention one. Her response was " All of them". LOL.... I will say that she did speak to me in the debate. I doubted her and was proven wrong. Yet she used the tactic of "talking down" and trying to "play it" like she caught someone taking cookies out of the cookie jar. (to Joe). I'm all for women being leaders and moving ahead.....But there's something, just something about her..... She played the "I caught you" card too far.... With her winks and all.
Then you have Joe. I'm not even sure what to say about him. I thought I did not know much about Palin, but now I'm left unsure of Joe. I will say that I'm not turned off by Joe. I do WANT change.
This would be so much easier if Hillary was still in the running. But she's not. I think I need another debate on the debate.... LOL...
It's funny... Way back in high school I was not into this at all.... And here I am, many years later, watching everything, lisening to everything about politics...... I have even been listening to :
http://www.npr.org/blogs/talk/ on the radio, of course......I am just so political now.....I care... I can make a difference....
Thursday, October 2, 2008
Wednesday, October 1, 2008
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