http://www.ewg.org/issues/humantesting/20041029/letter_20041015.php
Letter from
Kenneth A. Cook, President, Environmental Working Group to
October 15,
2004
Michael Leavitt
EPA Administrator
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Dear Administrator
Leavitt:
Environmental
Working Group is deeply troubled to learn that the EPA has decided
to make the lobbying arm of a powerful regulated industry its
"partner" in a major chemical research initiative. This
agreement relegates the public and independent scientists to second
tier status, and it suggests that any polluter or regulated industry
can become a full partner with the EPA if the price is right.
This is an
ominous precedent.
Specifically,
the U.S. EPA and American Chemistry Council (ACC), a lobbying
organization representing over 150 of the largest chemical companies
in America, signed a Cooperative Research and Development Agreement
through which ACC will provide approximately $2 million to the
Agency to collect data on young children's (ages 0-3) exposures
to several household chemicals, including phthalates, brominated
flame retardants, and perfluorinated chemicals.
According
to the Agency's website, "Results from this study will be
used to evaluate the potential for children's exposure to these
chemicals, determine the impacts of age and activity patterns
on exposure, and reduce the uncertainty in exposure and risk assessments
for children." Notably, the goal is to reduce uncertainty
in risk assessments, as opposed to reducing exposure and risk
from the chemicals themselves. To be clear: Environmental Working
Group strongly supports greater study of children's exposure to
chemicals, but not through a "partnership" between polluters
and the government that grants the regulated industry access to,
and power over critical aspects of study design, study methods,
data collection, data review and analysis, and data interpretation.
This partnership,
called the Children's Environmental Exposure Research Study, whose
ironic acronym is "CHEERS," essentially is a gift to
an industry that has a long, checkered history.
In the EPA's
September 22, 2004 news release announcing the study, the acting
director of EPA's Human Exposure and Atmospheric
Sciences Division
acknowledged that the Agency has "very little information
about how children may be exposed to chemicals in household products,
whether it is through the air they breathe, food they eat or the
surfaces they touch."
Instead of
assigning a qualified team of independent scientists to gather
this information using government funds, your Agency has instead
accepted industry funding and guidance from the makers of the
very chemicals in question.
In a document
labeled "intended for internal Agency use only," yet
publicly available for public download at EPA's CHEERS website
(http://www.epa.gov/cheers/basic.htm),
this study of young children's exposure to phthalates, brominated
flame retardants, and perfluorinated chemicals is referred to
as "the ACC study."
Children subjected
to these pesticides and chemicals do not have $2 million to represent
themselves in this study. How can your agency justify this unprecedented,
cozy relationship with an agency you are supposed to be policing?
Aren't you concerned that this mixing of corporate and government
science will communicate to the public that the government's stamp
of approval can be bought?
I call on
you to end this questionable relationship now, and instead put
scientists free of industry ties in charge of the study —
with no way for the industry to manipulate the outcome. Particularly
in the wake of recent controversies, your Agency should work to
avoid mixing corporate and government science.
Sincerely,
Kenneth A. Cook President