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Children's Health Protection

Advisory Committee Regulatory Re-evaluation Report - Office of Children's Health Protection

Report of the
Children's Health Protection Advisory Committee
to the U.S. Environmental Protection Agency
Regarding the Selection of Five Regulations
for Re-Evaluation

Submitted by
Dr. J. Routt Reigart, Chair
Children's Health Protection Advisory Committee
May 28, 1998
Report of the Children's Health Protection Advisory Committee
to the U.S. Environmental Protection Agency
Regarding the Selection of Five Regulations for Re-Evaluation


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 missions 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 used by the CHPAC in its deliberations was the development of seven screening criteria to select rules for re-evaluation that would positively impact children's health protection either substantively or procedurally (Attachment A). The CHPAC approached the assignment to identify five existing regulations from a holistic, health-based strategy. First, the CHPAC considered specific substances and routes of exposure that may pose a greater health risk to children and second, determined which regulatory provisions were applicable. For instance, if the CHPAC determined that new evidence suggests a reanalysis because of a potential risk to children for a particular substance, then it recommended that this information should be considered in 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:

  1. Mercury
  2. (Farm) Worker Protection Standard
  3. Triazine Pesticides
  4. Organophosphates and Carbamates
  5. Air Quality and Asthma

During the CHPAC's deliberation process, several critical issues that impact children's health 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 address 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 is hopeful that the broad recommendations for process improvements will receive expeditious action and contribute meaningful long term enhancements to EPA's efforts to protect children's health. The CHPAC expects EPA to report back on its recommendations to repropose or not repropose the selected regulations by December 1998, and is also hopeful that it will continue to advise EPA throughout its regulatory re-evaluation process.


Specific Standard to Re-Evaluate:

National Emission Standard for Hazardous Air Pollutants (NESHAP) for Chloralkali Plants

Other Focus Areas for Multimedia Strategy:

Water Quality Criteria Standard
Regulatory Determination for Electric (Coal-Burning) Utility Boilers
Hazardous Waste Combustion Rule
Medical Waste Combustion Rule
Municipal Waste Combustion Rule

The CHPAC recommends that EPA take a holistic approach to evaluate all sources of mercury emissions. Mercury is a relevant issue to more than one media (air, water), which contributes to its entry into the environment, for example, by electricity (coal-burning) generation, incineration and discharge into water sources. Human exposure occurs primarily through fish consumption. Mercury exposure is associated with adverse health effects in humans. Depending on dose, the effects can range from severe to less severe, most notably, neurological, developmental, and reproductive effects.

By the end of 1998, EPA is scheduled to complete a multimedia strategy addressing mercury. We support EPA's multimedia approach and schedule for the issuance of this strategy.

We encourage EPA to proceed diligently with implementation to protect children from mercury emissions, including those from municipal, medical, and hazardous waste combustion.

Although the CHPAC selected the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Chloralkali Plants for re-evaluation, EPA resources should not be diverted from the evaluation of other larger sources of mercury emission. Important criteria for its selection are that the standard has not been re-evaluated or revised since its promulgation in 1973, children's health was not considered in the original development of the standard, and new information and data based on peer reviewed science suggest that risks to children and the persistent and bioaccumulative nature of mercury were not considered during the setting of the standard.

The CHPAC recognizes the Water Quality Criteria Standard as one means by which the EPA can regulate the prevention of contaminated fish by mercury and ensure children's protection from hazardous levels of mercury. The CHPAC recommends that EPA address the largest sources of mercury emissions expeditiously and prevent further contamination of fish by revising the Water Quality Criteria Standard. Studies have shown that once mercury enters water, either directly or through air deposition, it can bioaccumulate in fish and animal tissue at the top of the food chain in concentrations much greater than those found in water.

Another specific concern is the emission of mercury from Electric (Coal-Burning) Utility Boilers (regulatory determination by the EPA is due in November 1998). Important criteria for its selection are that there is currently no regulation of hazardous air pollutant emissions, such as mercury, from electric utility boilers, and electric utility boilers are the largest contributor of overall anthropogenic sources of mercury emissions in the United States (EPA Mercury Report to Congress 1997).


Specific Regulations/Standards:

Worker Protection Standards (WPS)

Children may be exposed to pesticides through employment in farm work, by eating fruits and vegetables directly from the fields while at work, or by drift from field applications to neighboring residential areas and schools. Pregnant and lactating women who work in farm fields or reside in neighboring areas can also expose fetuses and neonates to pesticides.

The current (farm) worker protection standard has not considered these pesticide exposures to children. Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA has the authority to regulate these childhood and prenatal exposures to pesticides through the worker protection standard including labeling, reentry intervals, personal protective equipment, worker education and training, and posting and signs.

The CHPAC recommends that EPA expeditiously re-evaluate the worker protection standard in order to determine whether it adequately protects children's health. In its re-evaluation, EPA should, for example, consider using standardized data on size and age-specific weight and height for modeling children's exposure when more specific data on children's exposure to individual pesticides may be lacking.


Specific Regulations/Standards:

Atrazine Drinking Water Maximum Contaminant Level (MCL)
Atrazine Pesticide Tolerance

Atrazine is an herbicide that belongs to the triazine class. Atrazine has been linked to adverse health effects including cancer and birth defects. Atrazine has been detected in drinking water throughout the midwest and other parts of the nation. When EPA established the tolerance and 1991 drinking water standards for atrazine, children's differential exposure was not considered and children's differential susceptibility was not fully evaluated. New information has since becomeavailable to the EPA concerning the mechanism of action underlying its carcinogenic effect. Hormonal effects were further investigated and triggered the need for the re-evaluation of both the carcinogenic effects of this compound as well as the developmental and reproduction studies. Reviewing the tolerances and the established drinking water standard in concert will provide EPA with an opportunity to evaluate a chemical's impact on children's health via aggregate routes of exposure. Reconsideration of the tolerances and drinking water standard for atrazine should be given top priority in EPA's implementation of the Safe Drinking Water Act and the Food Quality Protection Act.


Specific Regulations/Standards:

Pesticide Tolerances for Methyl Parathion, Dimethoate, and Chlorpyrifos

EPA scientific panels have found that organophosphate and carbamate insecticides disrupt the central nervous system via a cholinesterase inhibition mechanism of toxicity. Because children's central nervous systems continue to develop until puberty, they are particularly vulnerable to the effects of some neurotoxins. Children can be exposed to these insecticides through food, homes, schools, employment, and other sources.

Data indicate that children's patterns of dietary intake are distinct from adults' patterns. When EPA established the tolerances for these insecticides, children's differential exposure was not considered and children's differential susceptibility was not fully evaluated. Of the 39 pesticides registered for use on food, thirteen are detected in food according to FDA and USDA pesticide residue data. Five of these account for 90 percent of the dietary risk of neurotoxicity and three (methyl parathion, dimethoate, and chlorpyrifos) represent the bulk of that risk. Reconsideration of the tolerances for these three pesticides should be given top priority in terms of data collection and other necessary steps in EPA's implementation of the Food Quality Protection Act.


Areas for Review:

Indoor Air Quality
Ambient Air Quality Standards (Particulate Matter (PM), Sulphur Dioxide (SO2))

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