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Children's Health Protection

Letter from Pamela Shubat, Ph.D., to Administrator Jackson Regarding Indoor Air Environments and Children's Health Protection


November 17, 2011

Lisa P. Jackson, Administrator
United States Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460

RE: Indoor Environments and Children’s Health Protection

Dear Administrator Jackson:

The Children’s Health Protection Advisory Committee (CHPAC) is writing this letter to urge renewed attention to address indoor environmental exposures from the prenatal period throughout childhood and adolescence in living and learning environments. There are many exposures in these environments which are or may be potentially harmful to children including allergens, endotoxins, other biological substances, pesticides, combustion byproducts, heavy metals, radon and volatile organic compounds. There are gaps in our knowledge regarding the exposure limits for children as well as the health impacts of these exposures. Additionally substandard housing, inadequate school buildings, overcrowding, and deteriorating conditions in indoor environments disproportionately impact the lives of disadvantaged children daily in living (home, shelters) and learning (schools, child care, Head Start) environments.

We applaud EPA and other federal agencies for promoting initiatives to address children’s health. EPA’s leadership role in the National Prevention Strategy Plan, promoting a cohesive federal response to prevention and working to align the EPA mission and assets with other federal agencies, is to be commended. Strategic directions, such as ‘Healthy and Safe Community Environments’ will promote affordable and secure housing as well as sustainable and economically vital neighborhoods. We also recognize that the subcommittees of the President’s Interagency Task Force on Environmental Health Threats and Safety Threats to Children is considering exposures in the living environment, yet since children spend much of their time in schools and child care facilities, the learning environment deserves as much attention. Young children in child care environments and Head Starts/Early Head Starts may be affected at a critical time in their development which can result in long-term impacts on health, life and welfare. Additionally, little has been done to establish exposure limits for the younger years which may be different than older children. In this letter, we recommend specific actions that EPA can take, both within the agency and with other key federal stakeholders, to advance the effort to reduce exposures to potential harmful indoor pollutants in living and learning environments. Attached to this letter is detailed information (Indoor Environment Report) that provides the context for these recommendations.

Intra-Agency Recommendations

Standards

  • CHPAC recommends that EPA develop standardized housing and school inspection protocols that objectively measure the full range of potential indoor pollutant exposures, based on the most recent scientific methods. These protocols should include consideration of previous use of residential or school facilities.
  • CHPAC recommends that EPA establish indoor exposure limits for pollutants that have the potential to cause adverse health effects or interfere with the normal growth and development of children. Given the potential number of exposures, we recommend that EPA prioritize those contaminants for which we have evidence of direct impact on children’s health and development.
  • CHPAC recommends that EPA identify, through current scientific knowledge and future research, indoor pollutant exposures based on location and type of housing (e.g. tribal, inner-city, rural, suburban, multifamily, single family, manufactured homes) and develops a unified approach to prevent and remediate indoor pollutants that affect children’s health and development based on these findings.
  • CHPAC recommends that EPA consider utilizing the consumer products Volatile Organic Compounds (VOCs) emissions standards, such as those set by the California Air Resource Board, to minimize children’s exposure to VOCs in the indoor environment.
  • CHPAC recommends that EPA leverage private sector construction development by working with United States Green Building Council’s Leadership in Energy and Environmental Design (LEED) and Enterprise Green Community Standards to add healthy homes and schools criteria to certification standards insuring that existing standards protect children. (For example link green building interests to healthy home interests.)

Education and Outreach

  • CHPAC recommends that EPA identify opportunities to work locally with state and tribal agencies, school districts, Head Start programs and child care facilities and utilize regional EPA staff to educate and to implement standardized environmental assessments and effective interventions.
    • EPA should assist in disseminating a standardized educational program (such as the EPA-sponsored Eco-Healthy Child Care® program) for childcare providers around indoor pollutant exposures in the childcare environment and schools.
    • EPA should continue to work with states, tribal communities and localities through the Clean, Green and Healthy Schools Initiatives and complete the State School Environmental Health Program Guidelines.
  • CHPAC recommends that EPA partner with school-based health centers to incorporate protocols which help students and their families identify environmental conditions in their home, school or other settings that have the potential to impact students’ health as well as encourage health center staff to work with schools to promote a healthy environment.
  • CHPAC recognizes the work by EPA to define and establish an integrated pest management protocol for living and learning environments. As the Agency re-focuses its efforts on children’s health and the indoor environment, CHPAC recommends expanded outreach to childcare centers and parents through local and regional children’s services. For example, community health workers and Parent-Teacher organizations may be partners in the dissemination of information and implementation of initiatives.
  • CHPAC acknowledges the work by EPA and its fellow federal agencies to address the critical children’s health risk of radon exposure. CHPAC recommends that the EPA utilize all resources available and partner with private and public organizations to educate, advocate and provide remediation for radon in the learning environment as well as the living environments.
  • CHPAC recommends that EPA promote reduction in use of potentially hazardous substances in products in indoor environments and promote adoption of consumer and building products and other materials demonstrated to be safe for children.
  • CHPAC recommends that EPA continue to promote and disseminate best practices and information for individual, public, professional and government audiences using effective communication strategies for control of indoor environmental exposures through:
    • Promoting and funding model programs that have been shown to be effective in learning and living environments.
    • Developing messages that highlight the link between childhood exposures and academic achievement.
    • Developing effective messages that link the economic benefits to promoting public health prevention in living and learning environments.
    • Minimizing exposures to pesticides (bombs and sprays) using integrated pest management strategies.
    • Developing communication strategies to disseminate current knowledge about green products in order to enable customers to make informed choices in selecting green cleaning products for the living and learning environments.

Further Research

  • CHPAC recommends that EPA support further research documenting and updating the extent of home contamination with toxic workplace substances, routes of exposure including indoor air, populations at greatest risk of take-home exposures, adverse health effects, previously unrecognized toxic exposures, and the effectiveness of take-home exposure prevention and remediation methods.
  • CHPAC recommends that EPA continue to explore the impact of climate change on the indoor environment. We recognize that EPA solicited a recent report from the Institute of Medicine which identifies many gaps in knowledge of how climate change will impact the level of indoor pollutants and health outcomes. EPA should work with other environmental health scientists to study these effects and to establish preventive and remediation measures, particularly for vulnerable populations.
  • CHPAC recommends that further research be undertaken by EPA to develop standardized testing methods and exposure limits for both pre-market and existing building materials that may cause disease or interfere with normal child development and academic achievement such as emissions of volatile organic compounds (e.g. formaldehyde) and other harmful agents. CHPAC further recommends that the Administrator’s efforts to reform the Toxic Substances Control Act (TSCA) include provisions that would enable EPA to test and regulate building materials and products to ensure that use of such products in children’s living and learning environments do not pose environmental risks to their health. For example, EPA’s existing authority to address lead-based paint hazards in housing is through Title X of the 1992 Housing and Community Development Act, which amended TSCA. CHPAC believes that testing building materials before they are used in construction and buildings is a far better way to protect health than our current system, which can allow hazardous materials and products to be used and then take action only after exposure and harm has occurred.
  • CHPAC recommends that EPA identify and research the efficacy of state, local and national environmental health champions to promote, educate and disseminate information on indoor air pollutants and health impacts. We further recommend that EPA use this information to identify best practices and strengthen EPA’s outreach and education efforts.

Inter-Agency Recommendations

Standards

  • CHPAC recommends that EPA collaborate with other federal agencies and programs, such as the Department of Education (ED), the Department of Health and Human Services (HHS) including Administration for Children and Families (ACF) and its Administration for Native Americans and Office of Head Start (OHS), to develop national indoor environment standards for healthier learning and living environments. After these national standards are created:
    • EPA should collaborate with ED and OHS to establish incentive programs for compliance with national standards and best practices for child care facilities.
    • EPA should engage accrediting organizations in requiring compliance with national standards in child care facilities and schools.
  • CHPAC recommends that EPA work with other federal agencies such as HHS, specifically Maternal and Child Health Bureau (MCHB), and Department of Housing and Urban Development (HUD) to standardize certification of community health workers and utilize them to implement evidence-based reduction strategies for harmful indoor exposures as well as educate residents at the community level.
    • CHPAC recommends that EPA fund, along with other agencies, community health workers to provide education in the home to teach residents regarding reduction of exposures to harmful indoor pollutants in at risk communities.
    • EPA should establish credentialing standards for community health workers (e.g. online certification).
    • EPA should revise current EPA tools to make them more useful for community health workers
    • EPA should partner with existing federal programs, such as MCHB home visiting program and Healthy Child Care America to train individuals, such as community health workers who are already in homes or child care facilities, to incorporate environmental assessment into their visits.
    • EPA should partner with existing federal programs to integrate environmental risk reduction messages into existing anticipatory guidance educational messaging in clinical and home settings (for example, Text4Baby and Bright Futures).
  • CHPAC recommends that EPA address vulnerable populations who are disproportionately exposed to indoor pollutants and, using Healthy Homes as a model, engage HUD to establish intermediate and long-term remediation strategies to reduce these disparities including establishing ventilation standards.

Partnerships

  • CHPAC recommends that the EPA actively participate in the Affordable Care Act implementation to promote the inclusion of activities that reduce environmental exposures and improve the management of chronic conditions related to poor indoor air quality.
    • EPA should work with HHS and Community Health Centers to test innovative models of care, explore nontraditional providers (community health workers), and integrate systems to promote healthy living and learning environments.
    • EPA should work with HHS to make sure that environmental assessment and remediation is part of the prevention standards and reimbursable by payers (such as managed care organizations).
  • CHPAC recommends that EPA partner with the HUD to require public and other federally assisted housing to be “smoke-free”.
    • EPA should promote “smoke-free” policies in homes and cars for all children.
    • EPA should support the availability of environmentally safe federally assisted housing for children with asthma (e.g., Seattle’s “Breathe Easy Homes”).
  • CHPAC recommends that EPA work with the ED, ACF, and OHS to implement policies that support professional development programs which provide school personnel (including school boards, principals, teachers, school nurses, building engineers, maintenance staff, food service managers, and coaches) with the knowledge and resources needed to maintain and promote healthy indoor school environments.

Surveillance

  • CHPAC recommends that EPA establish linkages with surveillance systems and health systems to track and link health and environmental outcomes. The establishment of electronic health records may permit greater opportunities for looking at population level trends.
  • CHPAC recommends that EPA work with the Centers for Disease Control and Prevention (CDC) to promote surveillance of diseases resulting from indoor pollutants such as asthma, developmental delays, intellectual disabilities, birth defects and cancer, in order to target environmental interventions to children and communities at greatest risk.
  • CHPAC recommends that EPA work with local leaders in the tribal communities as well as other federal stakeholders to identify indoor environmental pollutants specific to these communities.
    • EPA should collect data and establish a database for indoor pollutant exposures in tribal communities.
    • EPA should, in partnership with HUD, Indian Health Services, ACF, and CDC, work with tribal governments to reduce exposure to harmful indoor pollutants.
    • EPA should engage tribal governments to reduce exposure to molds, wood smoke, formaldehyde and other indoor pollutants related to the use of mobile homes on reservations.

CHPAC strongly urges EPA to consider these recommendations in order to close gaps in our knowledge regarding harmful indoor environmental exposures to children and to take the lead in convening leaders and stakeholders in order to reduce these exposures in the learning and living environments. In conclusion, CHPAC recommends that EPA should advocate for a public health approach to identifying and reducing harmful indoor environmental exposures to children, crossing agency boundaries and collaborating with other key stakeholders in this effort.

Respectfully submitted,

Pamela Shubat, Ph.D.
Chair
Children’s Health Protection Advisory Committee

attachment: Indoor Environment Report
cc:
Peter Grevatt, Director, Office of Children's Health Protection
Mike Flynn, Director, Office of Radiation and Indoor Air
Gina McCarthy, Assistant Administrator, Office of Air and Radiation
Cynthia Giles, Assistant Administrator, Office of Enforcement and Compliance Assurance
Lisa Garcia, Associate Assistant Administrator for Environmental Justice, Office of Enforcement and Compliance Assurance
Jim Jones, Acting Assistant Administrator, Office of Chemical Safety and Pollution Prevention
Louise P. Wise, Deputy Assistant Administrator, Office of Chemical Safety and Pollution Prevention
Steven Bradbury, Office of Pesticide Programs Director, Office of Chemical Safety and Pollution Prevention
Keith Matthews, Director, Biopesticides and Pollution Prevention Division, Office of Pesticide Programs, Office of Chemical Safety and Pollution Prevention
Wendy Cleland-Hamnett, Office of Pollution Prevention and Toxics Director, Office of Chemical Safety and Pollution Prevention
Tala Henry, Acting Director, National Program Chemicals Division, Office of Pollution Prevention and Toxics, Office of Chemical Safety and Pollution Prevention


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